Free OFAC 50% Rule Sanctions Check

Under OFAC's Fifty Percent Rule, any entity owned 50% or more, in aggregate, by one or more sanctioned parties is itself blocked, even though it never appears on the SDN list. The rule comes from OFAC's revised guidance of August 2014 and works by operation of law. OFAC never designates these entities or announces them anywhere; the blocking follows automatically from the ownership math. A subsidiary of a sanctioned company is blocked the moment the ownership threshold is met, and so is a subsidiary of that subsidiary, all the way down the chain.

This is the gap most screening programmes miss. A counterparty can pass an SDN list check cleanly and still be blocked property, because the list only names the parent. OFAC has been explicit that the compliance burden of finding majority-owned entities sits with you.

OFAC deliberately does not publish a list of entities blocked under the 50% rule. Ownership changes daily, aggregation across multiple sanctioned owners is hard to track centrally, and the agency has said that publishing a list would imply completeness it cannot guarantee. The result: the rule is binding, but the universe of entities it covers is something every compliance team has to work out for itself.

SanctScan closes that gap with a derived dataset. It is not an official list, and we label it accordingly: every match carries a "Derived, not individually listed" badge so your audit trail is precise about what was matched and why.

The dataset is rebuilt from scratch every day. We start with every sanctioned organization on the official OFAC SDN list, then match those organizations against GLEIF, the global legal entity registry established under the G20 and used by financial regulators worldwide. GLEIF records which companies consolidate which subsidiaries in their audited financial statements, and consolidation means majority ownership. From there we walk every ownership chain downward: a company majority-owned by a sanctioned entity is blocked, and per OFAC's guidance that blocked status carries down undiluted to companies it owns in turn. Every entity we find ends up as a normal screening record that you can search, monitor, and export like any other.

Every match shows its work: the sanctioned owner, the complete ownership chain with legal entity identifiers, and the date of the ownership data. The same provenance appears on screen, in the API response, and on the PDF certificate.

Honest answer: indicative, not exhaustive, and we print that on every match. GLEIF ownership data is audit-grade for what it contains; relationships are drawn from consolidated financial statements and verified against official registries. When this source flags an entity, the ownership link is almost certainly real. But GLEIF's coverage is strongest for regulated and multinational companies, and much of the private corporate world has no legal entity identifier at all. A match here is strong evidence. The absence of a match is not clearance.

Because the dataset is recomputed daily, it self-corrects in both directions: if an owner is delisted or a subsidiary is sold out of a sanctioned group, the derived entity disappears on the next refresh.

Open the match and read the ownership chain. It names the sanctioned owner at the top, every intermediate company, and the entity you screened at the bottom, each with its legal entity identifier and the as-of date of the ownership data. If the entity is relevant to your business, treat it as blocked pending your own verification and consult your compliance counsel. US persons dealing with property of an entity blocked under the 50% rule face the same strict liability as for a direct SDN hit.