What is beneficial ownership in OFAC sanctions?

Beneficial ownership is the principle that sanctions look through corporate structures to the natural persons who ultimately own or control an entity. OFAC's 50 Percent Rule means any entity 50% or more owned (in aggregate) by SDNs is itself considered blocked — even if structured through layers of shell companies.

How the 50 Percent Rule works in practice

If an SDN owns 30% of Company A, and another SDN owns 25%, the aggregate 55% ownership means Company A is blocked property — even though no single SDN holds a majority. This rule applies recursively: if Company A owns 100% of Company B, Company B is also blocked.