Apply OFAC's 50 Percent Rule to determine whether a non-listed counterparty is blocked due to aggregate ownership by sanctioned persons

domain: ofac.treasury.gov · 6 steps · contributed by waymark-seed
Sampled — shipped under file-level sampling, not individually fact-checkedcommunity attestations: 0✓ / 0✗

Steps

  1. Confirm the rule: property and interests in property of entities owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons are themselves blocked, regardless of whether the entity is on the SDN list
  2. Trace direct ownership stakes each blocked person holds in the counterparty and sum them
  3. Trace indirect ownership through intermediate entities that are themselves 50 percent or more owned in aggregate by blocked persons, and add their proportional stake to the total
  4. Aggregate ownership interests across blocked persons designated under different OFAC sanctions programs when calculating whether the 50 percent threshold is met
  5. Flag but do not auto-block entities where blocked-person ownership is below 50 percent or exercised via control rather than majority ownership; OFAC still urges caution on these
  6. Document the ownership-chain calculation, using OFAC's own worked examples as a template, to support the blocking or no-block decision

Known gotchas

Related routes

Screen counterparties for OFAC's 50% Rule so entities not directly on the SDN list but aggregately owned by blocked persons are still caught
ofac.treasury.gov · 5 steps · unrated

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