Defining OFAC Property Interests Beyond The 50% Rule

By Sean Kane and Joseph Schoorl (June 7, 2017, 1:29 PM EDT) -- Most companies are familiar with how U.S. sanctions can apply to designated parties and to entities owned 50 percent or more by such parties, as well as the risks that attend to entities in which designated persons maintain a significant ownership interest that is less than 50 percent. However, even if there is no such ownership interest, sanctioned parties acting as officers or representatives of nonsanctioned entities may have a property interest in certain transactions. Companies need to be mindful of how expansively a blockable "property interest" is defined and aware of the potential implications....

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