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Acams CGSS Exam - Topic 2 Question 16 Discussion

ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?
D) Yes; ABC Industries is a blocked entity due to aggregate ownership (50%) by two OFAC SDNs.
A) Yes; ABC Industries is a blocked entity due to ownership by one OFAC SDN.
B) No; ABC Industries is not a blocked entity since aggregate OFAC SDNs' ownership is below 50%.
C) No; ABC Industries is not a blocked entity since it is not listed as an OFAC SDN.

Acams CGSS Exam - Topic 2 Question 16 Discussion

Actual exam question for Acams's CGSS exam
Question #: 16
Topic #: 2
[All CGSS Questions]

ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?

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Suggested Answer: D

OFAC's 50 Percent Rule requires aggregation of ownership by SDNs and entities owned 50% or more by SDNs.

Ownership breakdown:

* Entity X (SDN) 30%

* Entity Y (owned 80% by an SDN) treated as an SDN contributes 25%

* Total SDN-derived ownership = 30% + 25% = 55%

Since aggregate SDN ownership exceeds 50%, ABC Industries is automatically considered a blocked entity, even though Entity Z is not sanctioned.

Options B and C are incorrect because explicit listing is not required---ownership triggers blocking. Option A is incorrect because one SDN at 30% alone is insufficient, but combined ownership is.


OFAC 50 Percent Rule (aggregation principle).

Treatment of entities majority-owned by SDNs as SDNs for ownership calculations.

Contribute your Thoughts:

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Lauryn
4 days ago
Wait, isn't 50% the cutoff?
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Evangelina
9 days ago
I think it's definitely a blocked entity.
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Luke
14 days ago
ABC Industries has 55% ownership by OFAC SDNs.
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Kayleigh
20 days ago
I’m a bit confused; I thought if you add up the ownership percentages, it could lead to a blocked status. So maybe option D could be correct?
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Valentine
25 days ago
I’m leaning towards option B because I recall that just having one SDN doesn’t automatically mean the entity is blocked if the ownership is under that threshold.
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Georgeanna
30 days ago
I think I saw a practice question similar to this where aggregate ownership was key. If the total ownership by SDNs is below 50%, then it might not be blocked, right?
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Refugia
1 month ago
I remember studying that if an entity is owned more than 50% by SDNs, it can be blocked, but I'm not sure about the specifics here.
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