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White & Case Ukraine News Update

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

White & Case Ukraine News Update

On August 13, 2014, the US Treasury Department's Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the "50% Rule," which established that an entity owned 50% or more, directly or indirectly, by a blocked party would be considered blocked by operation of law. The revised guidance establishes that aggregated ownership interests in an entity that total 50% or greater by one or more blocked persons are sufficient for that entity to be blocked by operation of law. OFAC also indicates that this revised guidance will be applied, as described below, to entities designated on the List of Specially Designated Nationals and Blocked Persons (SDN List) as well as entities included on the Sectoral Sanctions Identification List (SSI List).

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