OFAC: it keeps no country list, and entities 50 percent owned by a blocked person are blocked too (OFAC, Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions?)
Screening a holder means checking the person and its owners against the SDN list wherever it is located, and also knowing which countries carry country-wide programs. An unlisted company that a listed person owns half or more of is blocked too.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“The Office of Foreign Assets Control (OFAC) does not maintain a specific list of countries that U.S. persons cannot do business with. ... Some are broad-based and oriented geographically (e.g., Cuba, Iran). ... U.S. persons are prohibited from dealing with SDNs regardless of location and all SDN assets are blocked. Entities that an SDN owns (defined as a direct or indirect ownership interest of 50% or more) are also blocked, regardless of whether that entity is separately named on the SDN List.”
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in these 2 guides