No. OFAC’s 50 Percent Rule does not apply to persons blocked solely pursuant to the blocking sanctions of E.O. 14046. Unless an entity is itself a sanctioned person (as defined in E.O. 14046) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked. For more information, please see FAQs 923 and 924.
November 12, 2021