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Check the person and the source list
The Consolidated Screening List combines specified Commerce, State and Treasury lists as an aid. Commerce says apparent matches need further diligence and confirmation against the official source list. A fuzzy-name score measures similarity, not the chance a transaction is lawful.
Names, aliases, identifiers and addresses help match the actual party. Then identify the restriction associated with that particular list and person; not all list entries have the same effect.
Why multiplying the percentages can miss the result
OFAC’s 50 Percent Rule concerns relevant direct or indirect ownership of 50% or more in aggregate by blocked persons. In the cited illustration, a blocked person owns 50% of A, making A blocked; A owns 50% of B, which can in turn make B blocked. Looking only at 50% × 50% = 25% misses that intermediate-entity treatment.
Control without 50% aggregate ownership is not automatic blocking under this ownership rule. But other designation/blocking criteria or dealings involving a blocked representative can still matter. Below 50% is not universal permission.
The deal has separate restrictions
A distributor with no apparent name match still needs its relevant ownership and proposed goods, destination and use examined. Party screening alone does not settle technology, end-use, country-programme or authorisation requirements. A country connection is not necessarily a blanket ban either. Revisit the answer when the parties, ownership, goods or restrictions change.
Scope
- No live designation check, export classification, licence or transaction authorisation is provided here.
Next step
Resolve the actual identity, relevant ownership and transaction restrictions before relying on a clean-name result.
Sources & review notes
U.S. Department of Commerce, International Trade Administration
Passage, dates and research notes
official-guidance · Key Considerations; official source-list confirmation; search score
may be used as an aid
Read key considerations and tools plus source-list descriptions. CSL is an aid; apparent matches need diligence and official source confirmation. Fuzzy name score is similarity, not legal risk/clearance. No listed-person search or current designation outcome performed.
U.S. Treasury, Office of Foreign Assets Control
Passage, dates and research notes
official-guidance · Question, explanation and five ownership examples
50 percent or more in the aggregate by one or more blocked persons
Read full ownership explanation and examples. This source explains blocking ownership; control below 50%, other directives and designation grounds require separate analysis. No list search or ownership clearance was performed.
U.S. Department of the Treasury, OFAC
Passage, dates and research notes
official-guidance · Complete answer: ownership, control and other blocking criteria
speaks only to ownership and not to control
Read full answer. Control below 50% is not automatic blocking under this ownership rule; designation/other criteria and dealing with a blocked signatory may still matter. No country programme, general/specific licence or transaction is cleared.
Detailed rule records (1)
Commerce describes CSL as an aid requiring source-list and match diligence. OFAC’s 50 Percent Rule can block entities owned 50% or more in aggregate by blocked persons even without a separate name listing; ownership and control are distinct underFAQ 398.
Consolidated Screening List: use, source lists and limitations FAQ 401: indirect ownership under OFAC’s 50 Percent Rule OFAC FAQ 398: control versus ownership under the 50 Percent RuleKeep this reading in your learning library.
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