Beneficial Ownership

Beneficial ownership refers to the natural person(s) who ultimately own or control a legal entity, even when the entity is held through layers of intermediaries, shell companies, or nominee arrangements. Under OFAC's 50 Percent Rule, any entity in which one or more SDNs hold a 50% or greater aggregate ownership interest is itself considered blocked property.

The 50 Percent Rule

OFAC looks through corporate structures. If SDN A owns 30% of Company X and SDN B owns 25%, the aggregate is 55% — the entity is blocked even if neither SDN holds a majority individually. This rule catches shell companies and layered ownership structures designed to evade sanctions.