How Oligarch Sanctions Work

The oligarch sanction mechanics - and the 50% reach over assets.

Overview

Oligarch sanctions designate individuals - Putin, Lavrov, Abramovich, Deripaska - and block their assets and entities. The reach extends beyond the named person.

The mechanics

  1. OFAC designates the individual under a program authority (EO 14024, EO 13662)
  2. Their property and interests in property are blocked
  3. Entities owned 50%+ are treated as blocked (the 50% rule)

The ownership layer

Oligarch wealth runs through shell structures. The 50% rule blocks entities owned by designated persons even when never listed - ownership screening is the layer that catches them.

The screening shape

Screen the name, the owners, and the jurisdiction. The designated-owner scenario shows the workflow.

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