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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.

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