OFAC 50% Rule calculations with documented evidence.
Calculate aggregate sanctioned ownership under OFAC FAQ No. 401. GLEIF-based parent linkage, documented evidence, and clear limitations for compliance review.
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.
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.
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.
Explore the full platform
Questions buyers ask.
What is the OFAC 50% Rule?
Under OFAC FAQ No. 401, any entity owned 50% or more in aggregate by one or more sanctioned persons is itself considered sanctioned, even if it does not appear on the SDN list. This is known as the OFAC 50% Rule. US persons are prohibited from transacting with such entities.
How does Verifex calculate aggregate ownership?
Verifex traverses corporate ownership chains where source data supports it, sums sanctioned ownership percentages at each level, and flags entities where the aggregate equals or exceeds 50%. Calculations are documented with source references and confidence levels.
Is this a legal determination of blocking status?
No. Verifex provides analytical support to help compliance teams identify ownership-control risk direction. Final determinations of blocking status should always be made by qualified legal and compliance personnel.
What if ownership data is incomplete?
Ownership data varies significantly by jurisdiction. Where official registries are incomplete, Verifex supplements with manual-enhanced reports and clearly flags known data gaps. Every report includes analyst confidence levels and source limitations.