Glossary
OFAC rule stating that entities owned 50% or more in aggregate by blocked persons are also considered blocked, even if not named on the SDN List.
The rule operates by aggregation: if Person A (blocked) owns 25% and Person B (blocked) owns 25% of Entity X, then Entity X is blocked by the 50% rule. The ownership is calculated by voting shares, ownership interests, or other controlling interests.
OFACs 50% Rule provides that any entity owned in the aggregate of 50% or more by one or more blocked persons is considered a blocked person itself, even if the entity is not individually named on the SDN List.
Any entity that is 50% or more owned in aggregate by blocked persons. This can include shell companies, trading entities, investment vehicles, and operating businesses.
AI agents that screen only explicit SDN names miss the 50% Rule exposure. Your agent could process a payment to an entity not on any list but owned by blocked persons. Name-based screening should be complemented by entity resolution and ownership analysis.
agentmail screens names against the SDN list including aliases. For 50% Rule scenarios, we recommend combining agentmails fuzzy name matching with your own entity ownership data to catch indirect sanctions links.
The rule applies to entities, not addresses. However, if a wallet is owned by an entity that falls under the 50% Rule, transactions with that wallet are prohibited.
agentmail matches names against the SDN list with fuzzy matching. For full 50% Rule analysis, combine name screening with entity resolution data showing beneficial ownership structures.
The same strict liability penalties apply as if you transacted with a named SDN. The fact that the entity was not on the SDN List is not a defense.