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
1129. Do blocking sanctions issued by the State Department on May 19, 2023 on Polimetall AO apply to its corporate parent and affiliates?
On May 19, 2023, the Department of State designated Russia-based Polimetall AO pursuant to Executive Order (E.O.) 14024. These blocking sanctions apply only to this entity and any entities in which it owns, directly or indirectly, a 50 percent or greater inte ... Read more
1128. Under Executive Order (E.O.) 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation,” U.S. persons are prohibited from providing certain services to persons located in the Russian Federation. How will OFAC define those categories of services?
Section 1(a)(ii) of E.O. 14071 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the T ... Read more