In accordance with the Office of Foreign Assets Control 50% Rule, which entities would be considered sanctioned even if not listed on the Specially Designated National (SDN) List? (Select Three.)

The Office of Foreign Assets Control (OFAC) 50% Rule stipulates that any entity owned 50 percent or more, directly or indirectly, by one or more blocked persons is itself considered blocked, regardless of whether it appears on the Specially Designated Nationals (SDN) List. The ownership interests of all blocked persons must be aggregated.
- Option A is 98% owned by an SDN.
- Option B is 50% owned in aggregate by two SDNs (35% + 15%).
- Option D is 58% owned in aggregate by three SDNs (12% + 18% + 28%). All three scenarios meet or exceed the 50% ownership threshold, making the entities sanctioned.

C. The aggregate ownership by SDNs is 45% (20% + 25%), which is below the 50% threshold required for the entity to be considered blocked.
E. The aggregate ownership by SDNs is 48% (45% + 3%), which is below the 50% threshold required for the entity to be considered blocked.
F. The aggregate ownership by SDNs is 40% (10 x 4%), which is below the 50% threshold required for the entity to be considered blocked.

1. U.S. Department of the Treasury, Office of Foreign Assets Control. (2014, August 13). Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked. "Property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50 percent or more by one or more blocked persons... This is known as OFAC’s 50 Percent Rule. The property and interests in property of such an entity are blocked regardless of whether the entity itself is listed in the annex to an Executive order or otherwise placed on OFAC’s list of Specially Designated Nationals and Blocked Persons (the “SDN List”)."

2. ACAMS. (2023). Certified Global Sanctions Specialist (CGSS) Study Guide. Chapter 2: Sanctions Regimes and Lists. The guide explains the application of OFAC's 50% Rule, emphasizing the aggregation of ownership stakes held by multiple sanctioned parties to determine if the 50% threshold is met. (Specific section on OFAC's 50 Percent Rule).