Interviewee: Shadow blocked entities do not appear on the SDN list. These entities are considered blocked because they are owned or controlled by other blocked persons as a result of OFAC’s interpretive guidance regarding the 50 percent rule, including its aggregate 50% rule. There may now be many more blocked entities that do not actually appear on the SDN list. People have to be careful because they are still prohibited from transacting with these shadow entities even though they do not appear on the SDN list.

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