Frequently Asked Questions

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… 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… Read more

Recently Added FAQs

948. Does Directive 1 under E.O. 14038 prohibit U.S. persons from entering into derivatives contracts linked to new debt issued by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

Yes.  Transactions by U.S. persons and within the United States involving derivative products whose value is linked to an underlying asset that constitutes prohibited debt issued by a person subject to Directive 1 under E.O. 14038 are prohibited, unless… Read more

947. If a U.S. person entered into a revolving credit facility or long-term loan agreement for a person determined to be subject to Directive 1 under E.O. 14038 prior to December 2, 2021, what are the restrictions on drawdowns from that facility?  Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 90 days or less?

If a U.S. person entered into a revolving credit facility or long-term loan agreement prior to December 2, 2021, drawdowns and disbursements with repayment terms of 90 days or less are permitted.  In addition, drawdowns and disbursements whose repayment terms… Read more