OFAC 50% Rule

OFAC’s rule that an entity owned 50 percent or more, in the aggregate, directly or indirectly, by one or more blocked persons is itself blocked, even if not separately named on the SDN List. Stated in OFAC’s Revised Guidance on Entities Owned by Blocked Persons (13 August 2014), it makes the property of such entities frozen by operation of law. Control short of 50 percent ownership does not auto-block but warrants caution. In shipping it forces tracing the full ownership chain of a counterparty or vessel-owning company.