The Treasury Department’s Office of Foreign Assets Control maintains lists of restricted parties, including the specially designated nationals and sectoral sanctions identifications lists.
Under the so-called 50 percent rule, any entity owned 50 percent or more by an entity on the SDN or SSI lists is subject to the same restrictions as the listed entity.
Compliance with this rule can prove challenging, as many of the entities caught by the 50 percent rule do not appear on any U.S. government restricted party list. Instead, exporters must analyze an entity’s ownership structure to ensure compliance.
