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
1099. Do non-U.S. persons risk exposure to U.S. sanctions for facilitating transactions related to Chevron Corporation (Chevron) and its joint ventures in Venezuela that are authorized pursuant to Venezuela General License (GL) 41?
No. Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to U.S. sanctions for facilitating transactions or payments for or on behalf of, directly or indirectly, Chevron, its subsidiaries, joint ventures, or contractors… Read more
1098. Does Venezuela General License (GL) 41 authorize U.S. persons to provide goods or services for Chevron Corporation’s (Chevron) operation and management of its joint ventures (JVs) in Venezuela?
Yes, provided that such goods and services are for certain activities related to the operation and management of Chevron’s joint ventures in Venezuela, as specified in GL 41. Such activities include, among others, the production and lifting of petroleum or… Read more