OFAC制裁最关键也是最困难的一点就是“50%规则”的判断和适用,因为现实公司的控股情况往往是比50%规则预设的要复杂许多倍的! OFAC“50%规则”美国财政部官网及FAQ: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1521#:~:text=OFAC's%2050%20Percent%20Rule%20states,blocked%20person...
Brackett, Alex
revised guidance on 50% rule 72021-03 3 74 what is a license 52021-03 4 11 who must comply with OFAC regulations 92021-03 5 10 what countries do i need to worry about 172021-03 6 8 what must i do to get permissions 42021-03 7 6 Where can I find the specific details about the ...
OFAC’s 50% Rule The SDN list and SSI List apply not only to the companies named on the lists, but also to any other company that is 50% or more owned by a listed party. This means that businesses cannot simply screen a party’s name against the OFAC lists. They also must determine...
2. No 50% rule for the Cuba Restricted List. The State Department clarified that there is no “50% Rule” for companies owned or controlled by entities on the Cuba Restricted List. Specifically, the State Department stated in a header to the Cuba Restrict...
Office of Foreign Assets Control OFAC announced settlement agreement with Payward, Inc. Kraken online virtual currency exchange, in connection with 826 apparent viol