Pillsbury Winthrop Shaw Pittman

OFAC makes important update to ownership/control guidance

By Stephan E Becker, Nancy A Fischer, Aaron R Hutman and Stephanie J Rohrer

On 13 August 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since 14 February 2008, and may have important practical implications for how companies conduct due diligence, assess whether potential business associates or customers are blocked under US law and determine when it is safe to deal in or transfer the property of such persons.

OFAC previously has implemented guidance that an entity that is owned 50 per cent or greater by a blocked party would itself be considered blocked, even if the entity was not expressly identified on the List of Specially Designated Nationals (SDNs). Until the latest guidance, OFAC’s policy was not to combine ownership shares of different entities in applying the 50 per cent test…

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