Ownership risk

OFAC 50% Rule ownership-risk reports.

An entity may create sanctions exposure through ownership or control even if it is not directly listed. Verifex supports ownership-chain risk review where data is available — with explainable evidence you can share with counsel.

The risk

Why ownership matters

OFAC FAQ No. 401 states that an entity may be treated as blocked if 50% or more of it is owned — directly or indirectly in the aggregate — by one or more blocked persons. Recent enforcement (GVA Capital, $215.9M in 2025) demonstrates that missing indirect ownership chains carries significant penalty risk.

The challenge for mid-market firms: enterprise ownership intelligence platforms (Sayari, Kharon, Moody's Orbis) deliver depth at enterprise prices. Most smaller fintechs, funds, and exporters lack a cost-effective way to document ownership-risk review with defensible evidence.

Verifex sits in the gap: an API-first ownership traversal engine with GLEIF data, explainable calculations, and source-backed export — priced for mid-market teams.

Deliverables

What you receive

Ownership chain traversal

Recursive traversal of corporate ownership chains up to 10 levels deep, with cycle detection and intermediate holding-company resolution.

Sanctioned owner checks

Cross-reference each entity in the ownership chain against configured sanctions lists to identify blocked or designated parties.

Aggregate ownership calculation

Compute effective ownership percentages through intermediate entities, applying the OFAC FAQ No. 401 aggregation rule across the full chain.

Source-backed evidence report

JSON report with every ownership link, source reference, calculation step, and timestamp. Structured for legal review and internal compliance documentation. PDF export is on the roadmap.

Not legal advice. Verifex ownership-chain analysis is analytical decision-support, not a legal determination of blocking status. Source availability varies by jurisdiction and entity. Customers should validate findings with qualified sanctions counsel before making compliance decisions.