OFAC 50 Percent Rule: Ownership Aggregation, SDN Risk, and Sanctions Compliance Strategy

Executive Summary: The OFAC 50 Percent Rule is a foundational doctrine of U.S. sanctions enforcement. It provides that any entity owned, directly or indirectly, 50 percent or more in the aggregate by one or more blocked persons is itself treated as a blocked person. Even if the entity does not appear on the SDN List.... By: Friling Law