Corporate Crime analysis: On 17 November 2023, the UK’s Foreign, Commonwealth and Development Office (FCDO) together with the part of His Majesty’s Treasury responsible for sanctions implementation and enforcement, the Office of Financial Sanctions Implementation (OFSI), issued joint guidance on their approach to the ‘ownership and control test’ which determines the scope of UK asset freeze sanctions. Guidance alone is, however, unlikely to address the problems caused by the UK’s ownership and control test in practice. Diana Czugler, senior associate, and Alistair Jones, of Counsel, of Peters & Peters, consider the new guidance.