Thread Starter: ColoradoAML
Title: Re: Weird examiner question on Beneficial Ownership
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If a sanctioned person owns 50% or more of an entity, that entity is also sanctioned, regardless of whether they're listed. So yes, you risk violating OFAC by not screening BOs. https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1521#:~:text=OFAC%27s%2050%20Percent%20Rule%20states,blocked%20persons%20are%20considered%20blocked.
The beneficial ownership rule did not change 314(a) screening requirements, so you are not required to screen BOs against 314(a). See question 24: https://www.fincen.gov/sites/default/files/2016-09/FAQs_for_CDD_Final_Rule_%287_15_16%29.pdf
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