Sanctions ownership and control as one bar to the 50% line, every blocked share traced to its source
Every blocked share traced to its source; the 50% call made while the payment is held.
See one case, screen by screen ↓Sanctions Ownership and Control is software for bank sanctions teams that finds companies owned 50% or more by sanctioned persons, through every layer, even when the company is on no list. Seven agents build the ownership tree from registry extracts, read the customer's certification and trade documents, match every owner to the OFAC lists and add the blocked shares under OFAC's 50 Percent Rule. The answer is one bar against the 50% line, each part traced to its registry line, for a Sanctions Analyst to prepare and a Sanctions Officer to decide.
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Sanctions ownership and control starts from one rule: a company owned 50% or more, in aggregate, by people on OFAC's blocked lists is itself blocked, even when it appears on no list. Name screening finds names on lists, so it stays silent. To find these companies, an analyst builds the ownership tree layer by layer from registry printouts, reads the customer's own certification, matches every owner to the lists and adds the shares in a spreadsheet, while a held payment waits.
The math is easy to get wrong. OFAC counts the whole stake of a company that blocked persons own 50% or more, and never multiplies through one they don't; two listed holders of 25% each already reach the line. The customer's certification may contradict the registry, free-zone and offshore layers file little, and owners move shares just after a designation to look smaller on paper. A listed manager does not block a company, but adding that control to the percentage overstates the case, and leaving it out hides it.
Estimated split of one deep review (a three-layer tree with one offshore layer) by hand and with the solution, from the demo bank's design; not a published figure.
Seven agents build the tree through every layer, add blocked shares OFAC's way and replay transfers against designations; an analyst prepares and an officer decides.
Thursday, October 22, 2026, at Corvane National Bank. At 6:58 AM the payments hub holds a $1,846,500.00 wire from Harlow Ridge Machinery Inc. in Houston to Varnholt Logistics FZE in the Jebel Ali Free Zone, Dubai, for freight forwarding and bonded warehousing. Varnholt is on no list. The clock is four business hours: decide by 10:58 AM. Here is what happens next, screen by screen, in the working solution.
Nadia's reviews come from payment holds, trade finance, correspondent banking, list updates and periodic reviews: 41 open, 7 needing a decision, 8 ready to prepare and 15 still with the agents. Varnholt Logistics FZE leads with 2h 18m left. A banner says the registry data service did not answer from 6:10 to 6:25 AM, and that four trees were rebuilt.
“Varnholt Logistics FZE is on no list, but 52% of it is owned by a blocked person. The $1,846,500 wire must be decided by 10:58 AM.”
The Registry agent pulled three registry extracts, the Document reader read the certification and two trade documents, and the Identity agent matched Gennady Orlek (0.98) and Kasimir Volden (0.97) to the SDN list. The Ownership calculator stacks what blocked persons own: Orlek's 28% directly and Halcyon Bay's 24%. Orrin Tradeco's 3% and Calder Wynn's 45% stay gray, not counted. The total is 52%, two points over the line.
“Blocked under the 50 Percent Rule, though it appears on no list.”
The 24% part opens its path: Gennady Orlek owns 600 of Halcyon Bay's 1,000 shares, 60%, so Halcyon Bay is blocked too, and its 240 of Varnholt's 1,000 shares count in full. The tree shows nine nodes, every edge with its share and source, and the listed manager joined by a dashed line: control, not counted.
The Ownership calculator never multiplies through a company that blocked persons do not own 50% or more, and never adds control to ownership.
Varnholt certified on August 28 that Halcyon Bay is owned by private investors, none sanctioned, and that nothing material changed in 12 months. The registry says Orlek owns 60% of Halcyon Bay, and shows two transfers, on July 10 and August 21. Two conflicts and one gap are shown, never averaged, and the registry is preferred. One click drafts a request for documents, which a second person approves.
“Certification is wrong.” · “Certification omits them.”
Every value is a citation. R2 opens the Halcyon Bay registry extract from Cyprus, dated October 20, 2026, with the line that matters lit: Gennady Orlek, 600 of 1,000 shares (60%). Halcyon Bay was incorporated on May 29, 2026, and its registered office is a corporate services address shared by 212 companies.
Control concerns are listed under the bar and never added. Kasimir Volden, on the SDN list, is general manager and sole signatory. Orrin Tradeco, formed nine days before it bought 3% from Orlek, is owned by his former CFO. A clause lets Varnholt assign receivables to Halcyon Bay. The history shows Orlek at 55% before his June 12 designation, 48% on paper on July 10 and 28% on August 21, while the traced blocked share went 55%, 55%, 52%.
“The shares moved; they never left him.”
The Memo writer has drafted six paragraphs with 14 citations, which Nadia can edit. Send stays disabled until she ticks five checks: Halcyon Bay is 60% Orlek's, the registry's Orlek is the listed Orlek, he still holds 280 shares, and she has read the control concerns and the transfer history. She keeps the agents' proposal, Block at 0.97 confidence, with four reason codes: OWN-50, RST-1, CTL-1 and SRC-2.
Hinge fact: “If it were below 50%, Halcyon's 24% would not count, and the total would be 28%.”
Signed in as Nadia, the Decide screen refuses her: she prepared the review. The prepared case waits for the Sanctions Officer: 52% blocked, the recommendation and its four codes, and two flags, a listed signatory and two transfers after the designation.
“You prepared this review, so you cannot decide it. Separation of duties: a Sanctions Officer decides.”
Martin chooses between block, reject, clear and return to the analyst, each with its reason code. He blocks with BLK-50, property of an entity blocked under the 50 Percent Rule, and the note for the record is prefilled from the memo. A clear over the line would have gone to the Head of Sanctions to co-sign.
“Block the payment: funds go to a blocked, interest-bearing account; report to OFAC in 10 business days.”
The payments hub moves $1,846,500.00 to blocked account BLK-26-0091, and trade finance marks Varnholt and Halcyon Bay as blocked parties. The Memo writer drafts the report of blocked property, due November 5, 2026, and a notice to Harlow Ridge Machinery that names the regulation only; both wait for a second person. Adding both companies to the internal blocked-entity list waits for the Head of Sanctions. Referral FIU-26-2231 goes to financial intelligence and appears on no customer-facing view.
Blocked 1 hour 57 minutes after the hold, two hours inside the clock.
The same held wire, seen by four of the people it passes: what their week looked like, and what it looks like now.
Seven agents build the tree through every layer, add blocked shares OFAC's way and replay transfers against designations; an analyst prepares and an officer decides.
Opens a review from a payment hold, a trade finance request, a list update or a periodic review, runs the other agents in order, keeps the clock for the trigger and hands the prepared review to a named Sanctions Analyst.
Pulls a registry extract no more than 30 days old for every company in the chain: shareholders with share counts, officers and every dated transfer.
Reads the customer's ownership certification, invoices, agreements and bills of lading, and keeps every owner, officer, signatory and affiliate with its page.
Matches every person and company in the tree to the OFAC SDN and non-SDN lists and the bank's internal list, comparing name, birth date, nationality and identifiers.
Applies the 50 Percent Rule: adds blocked persons' direct shares and the whole stakes of companies they own 50% or more, builds the stack and lists the facts the answer hinges on.
Replays every transfer within 180 days after or 30 days before a designation, and flags drops below the line on paper, transfers to family, associates or new companies, and continued control.
Drafts the analysis memo for the Sanctions Officer with a source for every sentence, the fields of the report of blocked property, the customer notice and requests for documents.
Blocks, rejects or clears with a reason. The agents propose; a named person decides.
Ask about any counterparty, owner, share or rule, or ask for a draft. Every answer points to its source and opens the right screen.
Why is Varnholt blocked if it is on no list?
Because blocked persons own 52% of it, and OFAC treats a company owned 50% or more in aggregate by blocked persons as blocked itself. Gennady Orlek, listed on June 12, holds 28% directly. Halcyon Bay holds 24%; Orlek owns 60% of Halcyon Bay, so Halcyon Bay is blocked too and its whole stake counts.
What would change the answer?
Three facts. If Halcyon Bay were less than 50% Orlek's, its 24% would not count and the total would be 28%. If the registry's Orlek were a different man, it would be 0%; name, birth date and nationality all agree. If Orlek no longer held his 280 shares, Halcyon Bay alone would be 24%. Volden's control would not change the count either way.
Which other counterparties does Gennady Orlek touch?
On June 12 his listing touched 14 trees on file; 3 reached 50% and were blocked then. Varnholt was not on file: it arrived with today's payment.
Draft the report of blocked property
The draft is ready: $1,846,500.00 blocked on October 22, 2026 in account BLK-26-0091, beneficiary Varnholt Logistics FZE, owned 52% by Gennady Orlek through a direct stake and Halcyon Bay. It is due November 5, ten business days from the block. A Sanctions Officer who did not draft it approves it.
12 screens from the working solution, on its sample data. Pick one to see it large.
How blocked shares are added, what the restructuring watch flags, the clocks, who signs and which source wins. Every change is a change request the Head of Sanctions approves.
| Setting | Default | Choose from |
|---|---|---|
| Blocked when owned | 50% or more, in aggregate | Set by OFAC guidance; it cannot be raised |
| Indirect ownership | OFAC method | The whole stake of a company blocked persons own 50% or more counts; never multiplied through one they don't |
| Watch band | 40% | Reviews in the band are watched, and a clear needs the Head of Sanctions |
| Control | Recorded apart, never counted | Officers, signatories, proxies and receivable assignments |
| Restructuring look-back | 180 days after a designation, 30 before | Flag drops to within 5 points under 50%, and transfers to family, former officers and companies under 90 days old |
| Clocks | Payment held: 4 business hours | Trade finance 1 business day · correspondent 2 · designation ripple 2 · onboarding and periodic 5 |
| Approvals | Two people on every decision, report and notice | Three for a clear in the watch band or with a listed person in control · Head of Sanctions on list changes |
| Sources | Registry first; extracts no older than 30 days | Customer certification valid 12 months · conflicts shown, never hidden |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate from the demo bank's design volumes, not a published figure · “typical” = published rules (OFAC, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked, August 13, 2014, and OFAC FAQs 398–402; 31 CFR 501.603, reports of blocked property within 10 business days; 31 CFR 501.601, sanctions records kept 10 years, as amended effective March 21, 2025; 31 CFR 1010.430, BSA records kept 5 years; OFAC advisory on sham transactions, March 31, 2026; FFIEC BSA/AML Examination Manual, Office of Foreign Assets Control). Corvane National Bank and the people, companies, accounts and references named on this page are fictional — characters and sample data in the working solution.
Sanctions Ownership and Control is software for bank sanctions teams that finds companies owned 50% or more by sanctioned persons, through every layer, even when the company is on no list. Seven agents build the ownership tree from registry extracts, read the customer's certification and trade documents, match every owner to the OFAC lists and add the blocked shares under OFAC's 50 Percent Rule. The answer is one bar against the 50% line, each part traced to its registry line, for a Sanctions Analyst to prepare and a Sanctions Officer to decide.
Under OFAC's guidance of August 13, 2014, a company owned 50% or more, directly or indirectly, individually or in aggregate, by one or more blocked persons is itself blocked, even when it is not on the SDN list. The solution applies the threshold as written: exactly 50% counts as blocked, and the shares of different blocked persons are added together. Settings can also apply the EU and UK ownership tests to euro and sterling payments.
OFAC's way: the whole stake of a company that blocked persons own 50% or more counts, and nothing is multiplied through a company they don't. In the sample case Gennady Orlek owns 60% of Halcyon Bay, so Halcyon Bay's whole 24% of Varnholt counts, not 60% of it; Orrin Tradeco's 3% does not, because its owner is not listed. Control, such as a listed manager, a possible proxy or an assignment of receivables, is listed apart and never added to the 50%.
The Restructuring watch replays every dated transfer from 30 days before a designation to 180 days after, and shows the owner's shares on paper next to the traced blocked share. It flags drops to within 5 points under 50%, transfers to family, former officers and companies under 90 days old, and continued control, citing OFAC's advisory on sham transactions. It flags only; it never calls a transfer evasion.
A reverse search runs over every ownership tree on file, at every layer, and only trees whose blocked share moves reach a person. In the sample, the October 21 update added three names; the agents checked 6,214 trees, found 11 touched, opened reviews for the 2 that reached 50% on a 2-day clock, and put 3 on watch.
The payments hub moves the funds to a blocked, interest-bearing account, and trade finance marks the blocked parties. The Memo writer drafts the report of blocked property, due to OFAC within 10 business days, and the customer notice, which names the regulation only; neither leaves the bank until a second person approves. A referral to financial intelligence stays confidential and never appears on a customer-facing or relationship view.
Yes. Agents read, match, add and propose; they never decide, block, reject or release a payment, or send anything outside the bank. A Sanctions Analyst prepares and a Sanctions Officer decides, never the same person, and a clear in the watch band or with a listed person in control also needs the Head of Sanctions. Overrides need a reason code, and every step is kept with who, what, when, why and the evidence.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your sanctions procedures, approval matrix, clocks, reason codes and a sample of past ownership reviews, connected to your registry data, screening service, payments hub, trade finance and case management systems. It goes live once every quality gate has passed.
One verdict line, the license's conditions matched to your facts, every source dated.
1-min demoSanctions Alert ReviewEvery hit cleared identifier by identifier; true matches with the officer within the hour.
1-min demoPayment Sanctions ScreeningHeld payments released or stopped in minutes, every decision with its reason and time.
1-min demoWe'll run Sanctions Ownership & Control on a sample of your own past ownership reviews.