Useful Resource: EU Guidelines on Ownership and Control

Technically, that's not the title of the document. But it includes the following:

Ownership

1. The criterion to be taken into account when assessing whether a legal person or entity is owned entity or having majority interest in it. If this criterion is satisfied, it is considered that the legal person or entity is owned by another person or entity.

and another, more detailed section on control (which, unfortunately, due to the way it's formatted by the EU, does not cut and paste remotely well).

And you'll also notice that it's from 2013, a good year before the Ukraine-related guidance. So, OFAC was not first to be explicit…

Thanks to Dinesh Anand from ANZ for this. You learn something new every day.

Link:

EU Guidance

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