When sanctions reach the companies a listed person owns

A listing reaches beyond the name

An asset freeze covers the funds and economic resources that a listed person owns, holds or controls. Those include companies the person owns or controls, even when no list names them. A subsidiary of a listed bank, or a trading company held by a listed individual, can be covered without ever appearing on a list.

Each authority sets its own test for when a company counts as owned or controlled. The tests differ in the threshold, in whether the holdings of several listed persons are added together, and in how they treat control without a majority of the shares.

The three tests side by side

United States: OFAC’s 50 Percent Rule

Under guidance OFAC published on 13 August 2014, an entity owned 50% or more, directly or indirectly, in the aggregate, by one or more blocked persons is itself considered blocked. Its property and interests in property are blocked whether or not OFAC lists it. The holdings of persons blocked under different OFAC programmes are added together.

The rule speaks only to ownership, not to control. An entity that blocked persons control but own less than 50% of is not blocked by the rule, although OFAC may designate it in its own right. If blocked persons’ holdings later fall below 50%, the entity is no longer automatically blocked, but property already blocked stays blocked.

European Union: the Council’s Best Practices

The Council’s Best Practices for the effective implementation of restrictive measures, in their update of 3 July 2024, treat an entity as owned by another person when that person holds 50% or more of its proprietary rights or has a majority interest in it. The holdings of several designated persons are aggregated.

Control is a separate test. Its criteria include the right to appoint or remove a majority of the board, control of a majority of the voting rights under an agreement with other shareholders, and the power to exercise a dominant influence. The paper adds indications that warrant further analysis, such as a designated person who is by far the largest shareholder, a buy-back option on favourable terms, or a transfer of shares close to the date of designation. Ownership and control can be refuted case by case.

Making funds available to an entity owned or controlled by a listed person is, in principle, making them available to that person indirectly, unless it can be reasonably determined, case by case, that the funds will not be used by or for the benefit of that person. The paper describes itself as non-exhaustive recommendations that are not legally binding.

United Kingdom: OFSI’s guidance

OFSI’s general guidance, updated on 12 May 2026, treats an entity as owned or controlled by a person who holds, directly or indirectly, more than 50% of its shares or voting rights, who has the right to appoint or remove a majority of its board, or who, it is reasonable to expect, could ensure that the entity’s affairs are conducted in accordance with their wishes. Financial sanctions then apply to the entity in its entirety, although it may not appear on the UK Sanctions List.

OFSI would not simply aggregate the holdings of different designated persons, unless the shares or rights are subject to a joint arrangement between them or one of them controls the rights of another. Shares or rights held jointly count in full for each holder.

A worked example

Two persons, each listed by all three authorities, hold shares in a company that no list names. Other shareholders, none of them listed, hold the rest. The example is the one the EU Best Practices use.

Holdings through other companies

OFAC’s FAQs show how it counts holdings held through other companies. It does not multiply percentages along the chain. An intermediate company that is itself blocked passes on its whole holding; one that is not blocked passes on nothing.

The EU Best Practices and OFSI’s guidance apply their tests to holdings held directly or indirectly, but they do not set out a calculation for chains of companies.

What it means for screening

• Name screening does not find owned companies. A company covered through its owners appears on no list, so matching names against the lists does not return it. Finding it takes ownership data: shareholder and beneficial ownership registers, the company’s own disclosures and the parent records in the Global LEI System.
• Each regime applies its own test. A payment that falls under more than one regime has to clear each test that applies to it. A company that is not covered in the United Kingdom may be blocked in the United States.
• Ownership changes around a listing. The EU Best Practices name a transfer of shares shortly before or after a designation as an indication that the designated person may have kept control.
• Control can exist below the threshold. The EU and UK tests cover control through board appointments, agreements or influence, which shareholdings alone do not show.

What the directory shows

The directory’s sanctions page lists the institutions whose BIC or LEI an OFAC or EU listing cites. It records listings, not ownership: an institution that a listed person owns appears there only if a listing names it. Institution pages show the direct parent and the ultimate owner where the researched profile or the Global LEI System records them, and any reason an entity gives the Global LEI System for not reporting a parent. They are a starting point for an ownership check. The directory does not apply the ownership tests.

Sources

• Revised guidance on entities owned by persons whose property and interests in property are blocked, 13 August 2014. US Treasury, Office of Foreign Assets Control (OFAC).
• FAQs: Entities owned by blocked persons (50% Rule), including FAQ 398 on control, FAQ 401 on indirect ownership and FAQ 402 on divestment. OFAC.
• Restrictive measures (sanctions): update of the EU Best Practices for the effective implementation of restrictive measures, document 11623/24, 3 July 2024, section VIII “Ownership and control”. Council of the European Union.
• UK financial sanctions general guidance, section 4 “Ownership and control”, updated 12 May 2026. HM Treasury, Office of Financial Sanctions Implementation (OFSI).
• Institutions on the OFAC and EU sanctions lists, with the date of each list. Elucidate.

Reviewed 2 November 2026. A summary of the authorities’ guidance, not legal advice: the regulations and each authority’s own texts apply.

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