Featured FAQs
401. OFAC’s 50 Percent Rule states that the property and interests in property of entities directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons are considered blocked. How does OFAC interpret indirect ownership as it relates to certain complex ownership structures?
"Indirectly," as used in OFAC’s 50 Percent Rule, refers to one or more blocked persons' ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s). OFAC urges persons consider ... Read more
5. How do I determine if I have a valid OFAC match?
If you are calling about a wire transfer or other “live” transaction:Step 1. Is the “hit” or “match” against OFAC’s Specially Designated Nationals (SDN) list, one of its other sanctions lists, or targeted countries, or is it “hitting” for some other reason (i. ... Read more
Recently Added FAQs
1203. What does General License (GL) 115 ("Authorizing Transactions Involving Gazprombank Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?
GL 115 generally authorizes all transactions involving Gazprombank Joint Stock Company ("Gazprombank"), or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, related to civil nuclear energy. Civil nuclear energy mea ... Read more
1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?
No. Treasury's sanctions target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine. As a general matter, personal, non-commercial remittances are not the target of sancti ... Read more