export-controls

The OFAC 50 Percent Rule: Sanctions Ownership and the 2026 Sham Transactions Guidance

A practitioner's guide to the OFAC 50 Percent Rule — ownership aggregation, indirect ownership, FAQ 401 examples, the March 2026 Sham Transactions Guidance, the GVA Capital, IPI Partners, and Gracetown enforcement actions, and the BIS Affiliates Rule taking effect November 10, 2026.