OFSI has updated its general guidance to add new paragraphs on aggregation (para 4.14) saying: “When making an assessment on ownership and control, OFSI would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. …
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Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human...
United Kingdom