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

851. How will the following key terms in section 5(b) of the Hong Kong Autonomy Act (HKAA) be defined:  “financial institution” and “knowingly”? 

Section 2 of HKAA defines these terms as follows, which OFAC intends to incorporate into relevant regulations: “financial institution” – the term “financial institution” is defined to have the same meaning as a financial institution specified in section 5312… Read more

850. How does the Treasury Department determine whether a transaction is “significant” for purposes of section 5(b) of the Hong Kong Autonomy Act (HKAA)?

For purposes of implementing section 5(b) of the HKAA, the Secretary of the Treasury may consider the totality of the facts and circumstances when determining whether transactions are “significant.”  As a general matter, the Treasury Department may consider… Read more