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
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1043. What activities are authorized pursuant to Syria General License (GL) 22?
Syria GL 22 authorizes certain activities in non-regime held areas of northeast and northwest Syria in the following economic sectors: agriculture; information and telecommunications; power grid infrastructure; construction; finance; clean energy;… Read more
1045. How can I tell which areas of northeast and northwest Syria fall within the scope of Syria General License (GL) 22?
For the purposes of Syria GL 22, the Annex in GL 22 identifies areas of northeast and northwest Syria in which activities described in GL 22 are authorized as of May 12, 2022. Syria GL 22 does not authorize activities involving persons blocked pursuant to… Read more