Frequently Asked Questions

Featured FAQs

401. OFAC’s 50 Percent Rule states that the property and interests in property of entities directly or indirectly owned 50 percent or more in the aggregate by one or more blocked persons are considered blocked. How does OFAC interpret indirect ownership as it relates to certain complex ownership structures?

"Indirectly," as used in OFAC’s 50 Percent Rule, refers to one or more blocked persons' ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s). OFAC urges persons… Read more

5. How do I determine if I have a valid OFAC match?

Please take the following “due diligence” steps in determining a valid OFAC match. If you are calling about a wire transfer or other “live” transaction: Step 1. Is the “hit” or “match” against OFAC’s Specially Designated Nationals (SDN) list, one of its… Read more

Recently Added FAQs

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

Transactions and activities involving Iranian financial institutions blocked under E.O. 13902 remain authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by the Iranian Transactions and Sanctions… Read more

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?  

Pursuant to Section 12 of E.O. 13902, the prohibitions of E.O. 13902 do not apply to transactions for the conduct of the official business of the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees,… Read more