With the complexities of determining ownership levels vexing many international companies as they comply with ever-expanding sanctions laws, new guidance was issued this week by the Treasury Department’s Office of Foreign Assets Control regarding entities owned 50 percent or more in the aggregate by more than one blocked person.
Entities blocked by either an Executive order or regulations administered by OFAC are broadly defined to include any property or interest in property, tangible or intangible, including present, future or contingent interests. Since 2008, officials have operated under what is called the “50 percent rule,” a determination that any property or entity that is at least half-owned by an individual subject to U.S. sanctions is also flagged.
