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
938. What early-recovery-related transactions and activities are nongovernmental organizations (NGOs) authorized to engage in pursuant to the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on November 26, 2021?
The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain not-for-profit activities in Syria, including: humanitarian projects that meet basic human needs; democracy-building; education; non-commercial development projects… Read more
937. What does the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on November 26, 2021, authorize with respect to nongovernmental organizations (NGOs)?
The GL at § 542.516 of the SySR continues to authorize, subject to certain limitations, NGOs to engage in certain transactions and activities that would otherwise be prohibited in support of the following not-for-profit activities in Syria: Humanitarian… Read more