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
1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?
The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly ... Read more
1264. I am a non-U.S. person engaged in humanitarian activities specifically looking to send food, medicine, or medical devices to Cuba. What is my exposure to sanctions under Executive Order (E.O.) 14404?
As a general matter, U.S. sanctions under E.O. 14404 are not focused on disrupting the delivery of food, medicine, or medical devices to Cuba. The U.S. government does not intend to target non-U.S. persons under E.O. 14404 for engaging in transactions related ... Read more