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?
Please take the following “due diligence” steps in determining 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 othe ... Read more
Recently Added FAQs
1144. Does Venezuela General License (GL) 45A authorize U.S. persons to provide certain services, including refueling services, to blocked Conviasa aircraft listed in the Annex of GL 45A that are carrying out non-commercial flights between a third country in the Western Hemisphere and Venezuela?
1143. For the purposes of Venezuela General License (GL) 45A, what does the term “non-commercial” mean?
For the purposes of Venezuela GL 45A, “non-commercial” flights mean not-for-profit flights that are not intended to generate a profit for Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa), or any entity in which Conviasa owns, ... Read more