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Conceptual image illustrating OFAC enforcement of the 50 Percent Rule, focusing on complex ownership structures that can create constructively blocked entities owned 50 percent or more in the aggregate by SDNs.

Enforcement & Investigations · OFAC Sanctions

OFAC’s Enforcement of the 50 Percent Rule

February 28, 2024

The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) last civil enforcement action for 2023 involved insurance company Privilege Underwriters Reciprocal Exchange (“PURE”), and was a stark reminder of…