sanctions apply only through ownership, not control, of entities.4 This approach differs in the EU, where the sanctions can apply to any entity that is “owned or controlled” by a designated entity or individual. Sanctions Against Russia Continued 3 Importantly, to date, U.S. ![]() West Texas Intermediate crude prices rose $7.48, or 6 percent, to $99.58 a barrel, the highest since August 11, 2014. Moreover, these “50 percent rule” violations are subject to that exact same strict liability standard. 50 Percent Rule Enforcement Factors The settlement announcement sets forth three factors that may determine whether a civil penalty is appropriate for violations arising from the 50 Percent Rule. How Bureau van Dijk can help you comply with the tricky OFAC and EU "50% rule".
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