The OFAC 50% rule: three steps to enhance the control framework

The 50% rule prohibits or restricts transacting with entities not included on OFAC’s Specially Designated Nationals and Blocked Persons (“SDN list”) list, but majority owned by designated parties (so-called sanctioned-by-law parties). It impacts virtually all industries and jurisdictions.

No established standards or best practices exist to assist firms in setting policies and procedures for identifying and screening unlisted entities. Yet recent enforcement actions demonstrate that firms wit...

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