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
852. What did the October 27, 2020 amendment to the Cuban Assets Control Regulations (CACR) do?
On October 27, 2020, OFAC issued an amendment to the CACR, effective November 26, 2020, to remove from the scope of certain remittance-related general authorizations any transactions involving entities or subentities identified on the State Department’s Cuba… Read more
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