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
1268. Do I need to include a dispute resolution provision in my contract with the Government of Venezuela to fall within certain Venezuela General Licenses (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A)?
Yes. Certain Venezuela general licenses (GLs), including 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A, require that any contract for authorized transactions with the Government of Venezuela or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in ... Read more
1267. Do certain Venezuela General Licenses (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) require a choice of law provision in contracts with the Government of Venezuela?
No. Effective August 27, 2026, parties seeking to enter into a contract authorized by certain Venezuela General Licenses (GLs) (e.g., 46D, 47B, 48B, 50C, 51C, 52B, 54B, and 61A) with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Pet ... Read more