Frequently Asked Questions

869. If a person is subject to non-blocking menu-based sanctions described in section 235(a) of the Countering America’s Adversaries Through Sanctions Act (CAATSA), do the same non-blocking sanctions apply to entities owned 50 percent or more by the listed person?

… by Executive Order (E.O.) 13849 , these non-blocking sanctions do not apply to an entity owned 50 percent or more, individually or in the aggregate, directly or indirectly, by such sanctioned … and interests in property of persons on the SDN List are blocked, and any entity owned… Read more

577. I am a U.S. person holding accounts for or other property of RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. Does General License 14 allow me to unblock this property?

… or other property of RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest blocked as of April 23, 2018 remain blocked, except for the use in … other than RUSAL (including any other entity in which RUSAL owns, directly or… Read more

592. Does General License (GL) 15L authorize U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest)? Does GL 15L authorize U.S. persons to receive accelerated payments or voluntary prepayment pursuant to the terms of such loan or bond?

… and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) only to the extent such transactions are ordinarily incident and … involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a… Read more

579. Will foreign persons be subject to sanctions under CAATSA for engaging in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest?

… in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? … in activity with RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest? …

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?

… 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, … see FAQ #412 . The amendments to Directive 4 do not change the applicability of OFAC’s… Read more

248. How do I use the Minimum Name Score field and score slider bar?

… return only names that exactly match the characters entered into the name field. A value of 50 will return all names that are deemed to be 50% similar based upon the matching logic of the search tool. By lowering the match threshold the … return only names that… Read more

1139. Does the 50 Percent Rule apply to Directive 1 under Executive Order 14014, “Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise” (MOGE Financial Services Directive)?

… interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise … Does the 50 Percent Rule apply to Directive 1 under Executive Order 14014, “… Read more

573. A person designated under E.O. 13661 or E.O. 13662, or blocked by operation of law pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation holds an ownership interest of less than fifty percent in a U.S. company. In such a scenario, how does the U.S. company comply with U.S. sanctions?

… If one or more blocked persons in such a scenario does not hold a 50 percent or more interest in the U.S. company, the U.S. company is not itself blocked, but the … all property and interests in property in which the blocked person has an interest. See OFAC’s 50… Read more

659. Does Venezuela-related General License 12 authorize U.S. persons to export goods, services, and technology from the United States to Petróleos de Venezuela, S.A. (PdVSA) or any entity in which it owns, directly or indirectly, a 50 percent or greater interest during the wind-down period?

… of diluents) involving PdVSA or any entity in which it owns, directly or indirectly, a 50 percent or greater interest (other than ALBA de Nicaragua (ALBANISA) or any entity in which ALBANISA owns, directly or indirectly, a 50 percent or greater interest) …… Read more

1080. I am a U.S. person with an account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024. What am I required or allowed to do under OFAC sanctions with respect to such accounts?

… financial institution that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Accordingly, U.S. persons are … on filing initial and annual reports of blocked property with OFAC can be found at… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence