Scenario: Agent Pays a Designated-Owner Entity

The designated-owner scenario - the 50% rule in action.

The setup

Your agent pays a vendor company. The company name is not on the SDN list - but its sole owner is a designated oligarch.

The gap

• Name-only screening passes the company - no match
• The 50% rule makes the entity itself blocked
• One payment = one violation

The resolution

1. Ownership screening surfaces the designated owner
2. The 50% aggregate test triggers
3. The company is treated as blocked
4. The payment is refused and documented

The takeaway

Wallet + name screening is the first layer; ownership is the second. The 50% rule closes the shell-company gap - oligarch sanctions depend on it.