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Acams CGSS Exam - Topic 4 Question 13 Discussion

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.)
A) A company with an SDN holding a 98% stake in it and B) A company with an SDN holding a 35% stake in it, and another SDN holding a 15% stake in it and D) A company with an SDN holding a 12% stake in it, another SDN holding an 18% stake in it, and another SDN holding a 28% stake in it
C) A company with an SDN holding a 20% stake in it, and another SDN holding a 25% stake in it
E) A company with an SDN holding a 45% stake in it, and another SDN holding a 3% stake in it
F) A company with 10 SDNs, each holding a 4% stake in it

Acams CGSS Exam - Topic 4 Question 13 Discussion

Actual exam question for Acams's CGSS exam
Question #: 13
Topic #: 4
[All CGSS Questions]

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.)

Show Suggested Answer Hide Answer
Suggested Answer: A, B, D

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.

Contribute your Thoughts:

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Ricarda
4 days ago
Wait, how does the 50% Rule even work?
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Joseph
10 days ago
I think B is also sanctioned, right?
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Eleonore
15 days ago
A company with a 98% stake is definitely sanctioned.
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Dusti
20 days ago
D seems like it could be sanctioned too, but I can't recall if the individual stakes matter more than the total.
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Broderick
25 days ago
I practiced a similar question, and I feel like B might be tricky because the stakes add up to 50%, but I'm not completely confident.
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Jamika
1 month ago
I think A and C definitely qualify since they exceed the 50% threshold when combined.
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Shantay
1 month ago
I remember the 50% Rule, but I'm not sure if it applies to all the percentages listed here.
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