
TRAFEED
The BIS and OFAC 50% Rules: Exactly 50%, Aggregation, and Chains of Subsidiaries
Does exactly 50% ownership trigger the BIS and OFAC 50% rules? Are several owners' stakes added together? How are grandchild and great-grandchild companies counted? This guide works through the text of the rule and OFAC's numbered FAQ examples, and covers where the BIS rule's stay stands (it ends 9 November 2026) and how to check a counterparty's ownership.
2026-10-20Ryuta Hamamoto