Good Practice

Getting ahead of the 50% Rule

Author
Elizabeth ShinglerSteven Brotherton
+ About author

Elizabeth Shingler (Richmond) is a Senior Manager in the Global Export Controls and Sanctions practice of KPMG LLP. eshingler@kpmg.com

Steven Brotherton (San Francisco) is a Principal in the Global Export Controls & Sanctions practice of KPMG LLP and leader of the service line. sbrotherton@kpmg.com

KPMG: SMART PRACTICE
With the continued expansion of sanctions regimes, the 50% Rule’s relevance to export compliance groups is increasing. In short, the US 50% Rule provides that when a party is owned directly or indirectly 50% or more in the aggregate by one or more blocked persons, that entity is considered blocked. However, outside the United States “control” may be a factor in assessing whether the 50% Rule applies. While the complexity of ownership interests, combined with the difficulty o...

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