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In accordance with the Office of Foreign Assets Control 50% Rule, which entities would be considered sanctioned even if not listed on the Specially Designated National (SDN) List? (Select Three.)
Under the OFAC 50% Rule, an entity must be treated as a Specially Designated National (SDN) --- even if not named on the SDN List --- when:
One SDN owns 50% or more of the entity, OR
Multiple SDNs collectively own 50% or more of the entity (ownership must be aggregated).
Applying this rule:
A: 98% ownership by a single SDN Blocked (exceeds 50%).
B: 35% + 15% = 50% aggregate ownership by two SDNs Blocked (meets 50%).
C: 20% + 25% = 45%, which does not meet the threshold Not blocked.
D: 12% + 18% + 28% = 58% aggregate ownership by SDNs Blocked (exceeds 50%).
E: 45% + 3% = 48%, which is below 50% Not blocked.
F: 10 SDNs 4% = 40%, which is below 50% Not blocked.
Thus, only A, B, and D meet or exceed the 50% aggregate ownership requirement defined by OFAC.
OFAC ''50 Percent Rule'' Guidance: Entities owned 50% or more, directly or indirectly, singly or in the aggregate by one or more SDNs, are considered blocked.
OFAC Ownership and Control Interpretive Guidance detailing aggregation of SDN ownership percentages.