Glossary
Ownership vs control (EU)
The EU asks not only who owns an entity but who controls it in fact — through board appointments, decisive influence or the ability to direct it. A counterparty can pass an ownership test and still be controlled by a designated person.
A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.
Related terms
SDN vs sectoral sanctions The OFAC 50% Rule EAR99 and ECCN General vs specific licence