UK Updates Financial Sanctions Guidance on Aggregation
The U.K.'s Office of Financial Sanctions Implementation updated its general financial sanctions guidance to discuss aggregation. The new paragraphs say that OFSI doesn't simply aggregate different designated individuals' holdings in a company when making an ownership assessment unless the shares…
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are subject to a joint arrangement between the designated parties or one party controls the other's shares. "Consequently, if each of the designated person’s holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person," the guidance said.