Fifty Percent Rule

News & Analysis as of

Revised OFAC Guidance on "Shadow" SDNs

OFAC expands the scope of its 50% rule. On August 13, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “Revised Guidance on Entities Owned by Persons Whose Property and Interests in...more

New Sanctions Guidance Increases Due Diligence Burden on Companies

On August 13, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published guidance (“Revised Guidance”) that revises its 2008 guidance regarding how to treat entities that are owned or...more

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