![]() ![]() This means your customer as an entity may not be blocked, but you could be in violation if your customer is owned, in aggregate, directly or indirectly by a blocked party or parties with a 50% or more ownership stake. The most recent evolution of the 50 Percent Rule now means the rule applies when an entity is owned by more than one person under the SDN list if the combined total is more than 50%-for example, two people on the list each own 25% of a company. OFAC’s 50 Percent Rule blocks property and interests of entities owned 50% or more by parties sanctioned by the Treasury Department, even if they are not sanctioned by name on the list. The Specially Designated Nationals list should be reviewed for every export shipment. The EAR require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes SDGT, SDT, FTO, IRAQ2 or NPWMD. persons are generally prohibited from dealing with them. This list also includes individuals, groups and entities, such as terrorists and narcotics traffickers designated under programs that are not country specific. Review Specially Designated NationalsĪs we discussed above, OFAC sanctions include a list Specially Designated Nationals. The best practices that follow are important to ensuring compliance. OFAC screening isn’t as simple as checking a name against a file you have saved on your computer. With compliance, there’s no such thing as “too small to be noticed.” All companies must exercise due diligence to meet export-control responsibilities. And compliance isn’t something only for bigger companies-small- and medium-sized exporters are liable, too. ![]() Noncompliance with OFAC regulations may significantly impact your ability to conduct future transactions, as you could be subject to a steep monetary penalty and potentially even jail time. Counter Narcotics Trafficking SanctionsĪ complete list of sanctions programs is available on the OFAC website. ![]()
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