OFAC’s '50 Percent Rule' states that “any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person.”
Companies that don’t appear on a sanctions list, but are majority owned directly, indirectly, or in the aggregate by sanctioned actors, are considered "sanctioned-by-law," and present legal and reputational risk to businesses worldwide.
Kharon’s 50-Plus dataset includes thousands of such entities located across 100+ jurisdictions.
Kharon conducts sophisticated, multilingual investigations that utilize all primary source and other reliable documentation, to create the most comprehensive understanding of ownership by sanctioned actors.
COMPLEX OWNERSHIP STRUCTURES
Kharon tackles complex and opaque ownership structures with stakes as low as 1%, analyzing layered ownership chains that traverse multiple jurisdictions.
More than 30% of the companies with majority sanctioned ownership are three or more degrees removed from the sanctioned parent.
Ownership stakes can be dynamic and fractional. Kharon includes entities majority owned in the aggregate by multiple sanctioned parties.
DIVERSE INDUSTRY EXPOSURE: THE INCREASING COMPLEXITY OF SANCTIONS ON THE RISK CONTROL FRAMEWORK
Sanctioned-by-law" companies exist across a diverse array of industries and geographies. Kharon’s 50-Plus dataset provides unparalleled coverage for screening against sanctioned-by-law and shadow entities.
MANAGING SANCTIONS-RELATED RISK IN VENEZUELA: STATE-OWNED ENTERPRISES, CORRUPTION, NARCOTRAFFICKING, AND BEYOND
The U.S., EU, and other nations have stepped up sanctions pressure on Venezuela’s Nicolas Maduro and his inner circle for engaging in human rights abuses, political repression, widespread public corruption, and narcotics trafficking at the highest levels of government. This review demonstrates several common typologies of Venezuela sanctions-related risk through a series of case studies that help inform effective decision-making and risk control frameworks.
REGULATORY & POLICY GUIDANCE ON MANAGING SANCTIONS-RELATED RISK
In this white paper, Kharon examines sanctions-related risk typologies addressed in recent guidance and statements from U.S. regulatory and enforcement bodies. This review informs risk management controls consistent with increasing expectations by regulators for more expansive use of data, technology, and network analysis to detect financial crime and other high-risk activity.
