Records / Laws and rulings

OFAC revised guidance on entities owned by blocked persons: 50 percent in the aggregate (OFAC, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked (13 August 2014))

Several blocked owners are added together. A holder company whose owners are, between them, 50 percent or more blocked persons is blocked even though it is not on the list.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

In the source's own words
“any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person.”
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