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Sanctions Compliance

Sanctions screening, OFAC compliance, EU restrictive measures, PEP screening, and navigating complex sanctions regimes.

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About Sanctions Compliance Discussions

Dive into sanctions screening topics including OFAC compliance, secondary sanctions, the 50% ownership rule, fuzzy matching false positives, and screening list refresh best practices. This category helps compliance teams navigate the complex and fast-changing sanctions landscape.

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Answered

OFAC 50% rule: practical challenges with indirect ownership

by Marcus Williams · 1 month ago
4 Upvotes
3 3 replies

Frequently Asked Questions

Discussions include OFAC compliance, EU and UK sanctions regimes, secondary sanctions challenges, the 50% ownership rule for SDN-owned entities, fuzzy matching optimisation, false positive management, consolidated screening list refresh frequencies, and preparing for new designations. Members share screening tool comparisons and operational best practices.

Community members recommend a combination of tuning fuzzy matching thresholds per list and entity type, implementing whitelist management for confirmed non-matches, using contextual data such as date of birth and nationality alongside name matching, and regularly analysing disposition patterns to identify systematic false positive sources. Several threads compare vendor approaches to matching algorithms.

Secondary sanctions allow a country (typically the US) to penalise non-US entities that transact with sanctioned parties. Forum discussions cover the practical compliance challenges including screening for indirect exposure, understanding jurisdictional reach, managing correspondent banking relationships, and building policies that address both primary and secondary sanctions risk without over-blocking legitimate business.

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