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
927. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions and activities that would be authorized for U.S. persons pursuant to Executive Order (E.O.) of September 17, 2021, “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia”?
Non-U.S. persons, including nongovernmental organizations and foreign financial institutions, generally do not risk exposure to U.S. sanctions for engaging in, or facilitating transactions or payments for, activities that would be exempt or authorized for U.S… Read more
926. What activities are authorized pursuant to Ethiopia General License (GL) 2, “Certain Transactions in Support of Nongovernmental Organizations’ Activities”?
Ethiopia GL 2 authorizes certain transactions and activities involving nongovernmental organizations’ (NGOs) activities in Ethiopia or Eritrea, including: activities to support humanitarian projects and to meet basic human needs (such as, among other… Read more