In 2008, OFAC first addressed its 50% Rule, before updating it in 2014 for further clarity. The revised guidance issued in 2014 states that, “any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person.”
That simple sentence within a one-page guidance update actually contains several complicated sanctions messages. Download the white paper to unpack the implications of this critical compliance rule.