How to Comply with OFAC’s 50 Percent Rule
Webinar: 1 CCS Credit
The Treasury Department’s Office of Foreign Assets Control maintains lists of restricted parties, including the specially designated nationals and sectoral sanctions identifications lists. Under the so-called 50 percent rule, any entity owned 50 percent or more by an entity on the SDN or SSI lists is subject to the same restrictions as the listed entity. Compliance with this rule can prove challenging, as many of the entities caught by the 50 percent rule do not appear on any U.S. government restricted party list. Instead, exporters must analyze an entity’s ownership structure to ensure compliance.
This webinar will demonstrate how to conduct a 50 percent rule review, focusing on the following topics.
- identifying and analyzing ownership structure
- tools and resources to use in a review
- best practices for resolving ownership questions
- how and when to utilize an end-use assurance
ERIN CLARK is Senior Export Controls Advisor for Sandler, Travis & Rosenberg, P.A., based in San Diego, California. Ms. Clark has almost 20 years’ experience in global trade compliance. Her clients include a diverse range of U.S. and foreign entities from a broad array of industries, including aerospace, automotive, chemical, defense, electronics, energy, manufacturing, network systems, satellites, semiconductors and telecommunications.
JARED P. HOLLETT is an Associate with Sandler, Travis & Rosenberg, P.A., resident in the San Francisco office, and a member of its Export Controls & Sanctions Practice. He focuses his practice on the International Traffic in Arms Regulations and the Export Administration Regulations, along with the sanctions regulations administered by the Office of Foreign Assets Control.