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
1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?
No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46B, 51A, and 52, as described below. Subject to certain conditions, GLs 46B, 51A, and 52 authorize established U.S. entities to engage in certain transactions involving Petróleo ... Read more
1246. Does General License 52 authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?
No. A specific license will be required before any sale is executed in the Crystallex case.Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a sett ... Read more