Calder & Vance International Sanctions & Compliance Counsel

Glossary

The OFAC 50% Rule

An entity owned 50% or more, in aggregate, by one or more blocked persons is itself treated as blocked, even if it is not named. Ownership is traced through chains, which is where screening most often fails.

A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.

Related terms

SDN vs sectoral sanctions Ownership vs control (EU) EAR99 and ECCN General vs specific licence

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