OFAC ownership-rule workpaper

What does the ofac ownership-rule workpaper produce?

Prepare an exact, source-linked OFAC 50 percent ownership propagation calculation from a customer-verified blocking-status snapshot.

Use the exact local files and task-specific inputs listed below. Preparation and review stay in this browser. Inspect all findings before preparing the finalized pack.

What do you need before you start?

• Define your scope and approved method.
• Retain actual original evidence and reviewed source references.
• Resolve input errors before preparing a complete result.

What information do you enter?

Select the actual local sources and freeze the task-specific inputs below. Keep source files and complete findings private.

• Exact reference, organization, subject, responsible reviewer and preparation date.
• Your scope and policy reference, version, approver, approval date and actual supporting source IDs.
• Named task rows, relationships, rules and evidence annotations entered through the task-specific editor.
• Unchanged original files with exact filename, MIME type, byte count and SHA-256.

What you can download

Every result must identify its supplied facts, assumptions and unresolved items.

Fictional review report (PDF). Editable review (DOCX). Complete fictional pack (ZIP). Requires tailoring and responsible review. Samples use the finalized renderer.

How does the ofac ownership-rule workpaper work?

1. 1
   Define the evidence basis

   Exact reference, organization, subject, responsible reviewer and preparation date.

2. 2
   Enter task-specific records

   Validate distinct acyclic entities and direct ownership totals at most 100 percent. Seed only your declared blocked persons with linked verified status evidence. Propagate through verified aggregate direct interests of at least 50 percent, in topological order. Do not multiply effective economic ownership to substitute for blocking propagation. Retain contributing owners, unknown interests and unreported remainder.

3. 3
   Inspect complete findings

   Review exact calculations, source gaps and unresolved items.

4. 4
   Keep recoverable work

   Save drafts and exact original bytes in this browser. Restore a complete ZIP after validating tool identity, every original hash and full prepared results. Recovery clears payment and source authorization.

5. 5
   Prepare finalized evidence

   Prepare the complete pack, then download them free.

Method and sources

Apply the steps above to the supported inputs. Use the listed source sections to review the rule basis, assumptions and limits.

• OFAC FAQ 401. Indirect ownership examplesExplains aggregate ownership propagation through entities meeting the 50 percent rule. The workpaper requires a verified acyclic ownership snapshot and confirmed blocking-status evidence. It does not determine transaction authorization.Office of Foreign Assets Control. Reviewed 2026-10-09.
• OFAC FAQ 400. Control and blocked individualsControl and dealings involving blocked individuals require separate review. Below-threshold ownership is not clearance to transact.Office of Foreign Assets Control. Reviewed 2026-10-09.
• OFAC FAQ 402. Ownership changes and previously blocked propertyA later ownership change does not by itself authorize release of previously blocked property. This workpaper does not evaluate divestment legality or release property.Office of Foreign Assets Control. Reviewed 2026-10-09.

Common questions

What still needs review?

Original evidence bytes, annotations and customer rules remain in this browser. Original files are not saved to the cloud. Customer verification and approval are declarations. Mechanical results do not authenticate source facts, decide legal applicability, clear screening hits, authorize transactions, classify exports, file reports or establish total wealth.

No live sanctions refresh or automatic legal determination. Cycles and incomplete evidence remain unresolved. Control, program-specific prohibitions, divestments and release of previously blocked property require separate review.

At most 100 task rows, 100 KB input, 300 KB result and 500 KB workspace metadata. Original files support 20 files, 10 MB each and 25 MB total. Private cloud saving retains its separate 5 MiB file and 16 MiB total limits.

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