The OFAC 50% Rule: When Government Lists Are Not Enough
Revised guidance requires that businesses stay away from or limit their engagement with entities where subjects on the OFAC list have a 50% or greater ownership interest individually or in the aggregate. The catch: OFAC was not going to aggregate those interests or proactively publish them on any list. This new requirement necessitates a significant amount of research to map these holdings, which is something that most compliance departments and list providers do not have the resources to do. It also requires experience to conduct due diligence in multiple languages given the global nature of such holdings. This paper will help shed light on these new requirements and what you need to do to stay compliant.