The 50 Percent Rule OFAC. Identify Entities Owned by Blocked Persons

In this video I will cover what is the 50 Percent Rule OFAC has established to identify blocked entities. We will go through 5 examples, and see how direct and indirect SDN connections contribute to the decision to block Entities Owned by Blocked Persons; particularly for complex company structures.

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▬▬ CHAPTERS ▬▬
0:00 - 50 Percent Rule OFAC Intro
1:02 - What does the OFAC’s 50 Percent Rule say?
2:07 - 50 Percent Rule OFAC example 1
2:43 - 50 Percent Rule OFAC example 2
3:57 - 50 Percent Rule OFAC example 3
5:03 - 50 Percent Rule OFAC example 4
6:10 - 50 Percent Rule OFAC example 5

✅ References:

DISCLAIMER:
This video is intended for general informational or entertainment purposes only. The information in this video is not intended to replace legal advice. The views and opinions expressed in this video are those of the speaker/s and do not necessarily reflect the original policy or position of people, institutions, or organizations that the speaker/s may or may not be associated with in professional or personal capacity, unless explicitly stated. Furthermore, no endorsement of any criminal activity is expressed or implied.
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[Rockytoce]

Thank you for explaining the 50% rule as clearly as possible, keep em coming please .

[saleem]

Hi there, I’d like to thank you, today I passed and became Certified Global Sanctions Specialist… I watched your this video and it helped me a lot. There were around five questions on same 50 percent rule in my exam and I marked them right.
Keep up the good work and thanks again.

[Sarumanthewhite]

Very useful video, thank you Sir for making the OFAC 50% easier for us to understand, the diagrams are really well made!~

[biswajitjena]

Perfect content without shit...
Soon you will reach 1 million

[casmartin]

Hi there Marco! Firstly, thank you for taking the time out to share your wealth of knowledge and experience with us all, you are seriously a tremendous help!

I have a question about the ownership and structures as I'm a little confused. In example 1, if Blocked Person X owns 50% of company A, and company A owns 50% of company B, I don't quite understand why Blocked Person X doesn't own 25% of company B, but also owns 50% of company B?

And with example 3, if BP X owns 50% of entity A and 10% of Entity B, and A owns 40% of entity B, I'm confused as to why BP owns 40% and not 30%?

I have no actual experience in AML but I'm trying to get into the industry so do watch your content.
Thank you for all that you do 👍🏾

[qhdpcuq]

Hi Marco, very interesting video. Congrats and well done for the good work!
I've got a question for which i cant find any answer online....
Blocked Company A is the Nominee Shareholder of Company B which is indirectly owned (the UBO details are Officially registered) with 100% of the shares from an unblocked person who is also the only Bank signatory and uses Company A just as a service provider (Nominee).
Is Company B considered blocked? Tough one hahaha!