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
874. I am a United States person seeking to divest my holdings of covered securities before the relevant deadline stated in Executive Order 13959, as amended (E.O. 13959). For purposes of E.O. 13959, what types of activities are permitted to effectuate such divestment?
Any transaction (including purchases for value and sales) entered into on or before 11:59 p.m. eastern standard time on November 11, 2021, solely to divest, in whole or in part, from securities that any United States person held as of 9:30 a.m. eastern… Read more
873. How does Executive Order 13959, as amended (E.O. 13959), define the term “transaction”?
Section 4(e) of E.O. 13959 defines the term “transaction” as the purchase for value, or sale, of any publicly traded security.