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Did you read OFAC FAQ 936?

It says that Hidri Trust and Red Sea Trading Corporation are not subject to the 50 Percent Rule. How does that happen?

Section 2(b) of Executive Order includes the following:

No entity shall be blocked pursuant to this order solely because it is owned in whole or in part, directly or indirectly, by one or more sanctioned persons, unless the entity is itself a sanctioned person and the sanctions in section 2(a)(i)(A) of this order are imposed on the entity.

Executive Order 14046, Section 2(b)

So, because of this wording, the 50 Percent Rule does not apply to the Ethiopia-related program. Subsidiaries need to be explicitly designated.

You have to wonder how many folks knew that before today’s designations. Mr. Watchlist is embarrassed to admit that he did not….

Categories: 50% Rule Ethiopia Sanctions Executive Orders Frequently Asked Questions (FAQ)

eric9to5

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