The report examines how ownership and control rules extend financial sanctions beyond persons and entities expressly named on sanctions lists. A company may remain formally unlisted while its assets or transactions are restricted because of its ownership structure, governance arrangements or the practical influence of a designated person. The same corporate structure can nevertheless produce different legal outcomes in the United States, the European Union and the United Kingdom.

The analysis compares three distinct approaches. In the United States, OFAC’s framework focuses on aggregate direct and indirect ownership of 50% or more by blocked persons, while control without the relevant ownership threshold does not by itself trigger automatic blocking under the 50 Percent Rule. The EU framework combines ownership criteria with separate concepts of control and the possibility of rebutting relevant presumptions. In the United Kingdom, the analysis extends beyond shares and voting rights to appointment powers and the ability to determine how a company conducts its affairs. A single “international ownership percentage” can therefore be misleading.

Particular attention is given to indirect ownership and actual management. The report explains why simple multiplication of economic interests does not always reproduce the legal result and why a registry extract alone cannot establish control. Relevant evidence may include appointment and removal rights, budget approval, banking mandates, financing arrangements, shareholder agreements and mechanisms through which economic benefits are received.

The report also examines Mints, Litasco and EM System, together with the historical example of the removal of En+, Rusal and EuroSibEnergo from US sanctions following changes in ownership and governance. These examples are used to distinguish proven control from assumptions, assess corporate restructuring and determine whether formal changes have genuinely removed the mechanisms through which influence was exercised.

ARGA’s practical approach follows a structured sequence: identify the person, determine the applicable sanctions regime, establish ownership rights, assess actual management, define the relevant asset or transaction and select the correct review procedure. The resulting file should allow another reviewer to trace the path from the corporate facts to the specific sanctions consequence. The report’s central conclusion is that ownership and control must be assessed in relation to a particular entity, legal regime, date and transaction, rather than through a broad assumption about the origin of a business or its association with a designated person.