Analytical support, not legal advice
OFAC 50% Rule calculations are provided as analytical support to help compliance teams identify ownership-control risk direction. They are not a legal determination of blocking status. Final decisions should always be reviewed by qualified legal and compliance personnel.
Capabilities
How Verifex supports OFAC 50% Rule workflows.
Aggregate ownership calculation
Sum sanctioned ownership percentages across direct and indirect holdings where source data supports it. Flag entities that may breach the 50% threshold.
GLEIF-based parent linkage
Use Legal Entity Identifier data to map corporate hierarchies where available. Direct parent and ultimate parent relationships improve ownership-chain visibility.
Corporate structure traversal
Traverse ownership chains through subsidiary relationships. Calculate aggregate sanctioned ownership at each level of the corporate tree.
Documented evidence
Every ownership calculation is logged with source data, percentages, calculation method, and timestamp. Retrievable for compliance review and audit reconstruction.
Clear limitations
Coverage varies by jurisdiction. Where official registries are incomplete, reports include known data gaps and analyst confidence levels. Not a substitute for legal review.
Risk direction, not legal determination
Results flag ownership-control risk direction. They do not constitute a legal determination of blocking status. Final decisions require qualified legal and compliance review.
Example workflow
How ownership risk propagates.
Sanctioned Owner A
35% ownership
Sanctioned Owner B
35% ownership
70% aggregate ownership
Counterparty Risk Detected
Sanctions exposure triggered by 50%+ aggregate beneficial ownership.
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