Key takeaways:

• Last week, OFAC revised its guidance on the circumstances under which an entity that is not itself designated for sanctions is nonetheless subject to US sanctions because it is owned 50% or more by a sanctioned person.
• OFAC now requires that, for purposes of calculating the 50% threshold, all ownership interests of sanctioned persons are aggregated.
• OFAC simultaneously released new FAQs that clarify certain related issues, including a statement that US persons cannot negotiate, contract or otherwise transact with a blocked person even if that blocked person is acting on behalf of a non-sanctioned company.