Not sure I understand. We're required to freeze or block funds going/coming from SDNs. If we say, "he only has 21.5% ownership" how does that translate to compliance? We also don't know whether or not the SDN is receiving benefit behind the scenes.
398. Does OFAC consider entities over which one or more blocked persons exercise control, but do not own 50 percent or more of, to be blocked pursuant to OFACâ€™s 50 Percent Rule?
No. OFAC's 50 Percent Rule speaks only to ownership and not to control. An entity that is controlled (but not owned 50 percent or more) by one or more blocked persons is not considered automatically blocked pursuant to OFAC's 50 Percent Rule.