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SANCTIONS-COMPLIANCE5 MIN READ

Quick Reference: 50 Percent Rule Pocket Guide

Recall the practical ownership checks needed before clearing a sanctions-sensitive entity.

Objection The entity is not on the list, so ownership is irrelevant. Use when a clean entity screen is being treated as final. Your line The name screen is one layer. We still need to know whether blocked-person ownership reaches the aggregate threshold directly or indirectly. Do not let clean entity screening substitute for beneficial ownership review. It explains why ownership is a separate sanctions control question and prevents a clean name screen from being mistaken for a complete sanctions review. Compare Ownership versus control Keep the concepts separate so the rationale stays precise. Recall What percentage triggers the core…

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