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373. Do the prohibitions imposed pursuant to the Directives also extend to entities owned 50 percent or more by one or more entities identified by these Directives, as per revised guidance OFAC issued on August 13, 2014?


Yes, these prohibitions apply to the named persons, their property, and their interests in property, which includes entities owned 50 percent or more by one or more persons identified as subject to the Directives.

On October 31, 2017, OFAC amended and reissued Directive 4 in accordance with Section 223(d) of the Countering America’s Adversaries Through Sanctions Act (CAATSA) (Pub. L. 115-44). For additional information regarding what amended Directive 4 prohibits, see FAQ #412. The amendments to Directive 4 do not change the applicability of OFAC’s 50 percent rule in the Directive 4 context. The references to “33 percent or greater ownership” and “ownership of a majority of the voting interests” in subsection 2 of Directive 4 refer to a Directive 4 SSI entity’s ownership interest in a deepwater, Arctic offshore, or shale project.

Date Released
October 31, 2017