Sanctions Screening
50 Percent Rule
Quick answer. OFAC’s 50 percent rule treats an entity as blocked if one or more blocked persons own it 50 percent or more in aggregate, even when the entity itself is not on the SDN list. Sanctions screening means checking names against current sanctions lists and writing down the result. Software helps only if it shows the list date. OFAC’s 50 percent rule can block an entity that is not itself named, based on ownership.
Official office
Office of Foreign Assets Control
Steps
-
Show the list version
A tool that cannot display the SDN file date is not ready.
-
Escalate possible matches
Someone named in the policy compares identifiers. “Dismiss” without a note is not a file.
-
Ask the ownership question separately
50 percent aggregation is not on the SDN search page.
-
Keep OFAC compliance as a repeatable process
One manual search is a sample. A program has an owner and a refresh cycle.
OFAC’s 50 percent rule is about ownership, not names
A clear name search on the company does not answer the ownership question. You need the ownership facts from the customer, not from the SDN file alone.
This page is not a legal opinion on aggregation, indirect ownership, or a specific transaction. If the ownership is close to the line, get counsel. We can still pull the public entity record and the OFAC name results.
A program, not a single green check
False positives are similar names. Clear them by comparing date of birth, address, and ID, and keep that comparison. Lowering the match threshold to empty the queue hides names. OFAC will not choose the threshold.
The 50 percent rule is an ownership test. A clear SDN search on the company name does not answer it. You need ownership facts. This site will not give a legal opinion on a close case. We can still pull the public entity record and the OFAC name results.
Common mistakes
- Trusting a score with no list date.
- Deleting weak matches with no write-up.
- Assuming a clear name search solves ownership.
- Treating screening software as a government certificate.
Questions
What is sanctions screening software?
A tool that loads official lists and scores names. It still needs a person and a current file.
What is a false positive?
A possible match that identifiers show is not the listed person. Document the comparison.
What is the 50 percent rule?
OFAC treats an entity owned 50 percent or more in the aggregate by blocked persons as blocked, even if the entity is not on the SDN list. Get counsel for a real transaction.