Sanctions & Tariff Lookup
The OFAC 50 Percent Rule, explained
Last updated · Starry Night
A clean result on the SDN List does not always mean a company is clear. Under OFAC's 50 Percent Rule, a company owned 50% or more by blocked persons is itself blocked, whether or not OFAC lists it by name.
What the rule says
OFAC's FAQs on the 50 Percent Rule (FAQs 398 to 402) explain it. FAQ 399 says the rule applies to entities owned 50 percent or more in the aggregate by one or more blocked persons, as OFAC set out in revised guidance on August 13, 2014. FAQ 401 covers entities owned directly or indirectly.
- Aggregate: two blocked people owning 25% each make 50%, so the company is blocked.
- Indirect: ownership passes through holding companies. If a blocked person owns 50% or more of company A, and A owns 50% or more of company B, B is blocked too.
- Ownership, not control: the rule turns on ownership. OFAC's FAQs discuss control separately; read them before relying on a company being controlled but not owned.
What this means for screening
- Screen the company's name, as usual.
- Find out who owns it: ask for an ownership chart, or read the corporate registry where the company is incorporated.
- Screen each owner, including the owners of any holding company in the chain.
- Add up the stakes held by any owners who are blocked. 50% or more in total means you treat the company as blocked.
- Write down what ownership information you had and when you checked it.
What a list tool can and cannot do
Any list-based tool, this one included, answers "is this name on a list?". It cannot see who owns an unlisted company. Screening the owners as separate names is the part a tool can help with.
Screen a company and all its owners in one run
The screening record page screens up to 500 customers, suppliers or vessels at once against the U.S. Consolidated Screening List (OFAC, BIS and State Department lists), the UN Security Council Consolidated List, the UK Sanctions List and the EU consolidated financial sanctions list, with name matching that handles word order, transliteration variants and small typos, and builds a dated PDF record of the run. On-screen results and a PDF marked PREVIEW are free; a $29 one-time unlock removes the watermark for 24 hours. Names are not stored.
Checking a few names while you work in Claude? The free Sanctions & Tariff Lookup connector screens a name from a chat and shows each possible match with its list, programs and identifiers. No sign-up with Starry Night is needed.
This guide explains public rules and OFAC guidance in plain English. It is not legal advice; for a decision about a specific party or transaction, talk to sanctions counsel or contact OFAC. Sanctions & Tariff Lookup is published by Starry Night and is not affiliated with OFAC, the Department of Commerce, the State Department, the UN, the UK government or the European Commission.
Questions
Does the 50 Percent Rule add up ownership by different blocked persons?
Yes. OFAC FAQ 399 says the rule applies to entities owned 50 percent or more in the aggregate by one or more blocked persons.
Does the rule cover indirect ownership?
Yes. OFAC FAQ 401 covers entities directly or indirectly owned 50 percent or more in the aggregate by blocked persons.
Will a sanctions list search find these companies?
Not reliably. A company blocked by ownership is often not named on any list, so a name search returns no match. You need to know who owns it.