The U.S. & EU 50 Percent Rule: Understanding Ownership Rules & Regulations to Better Manage Risk

The 50 Percent Rule introduces a unique compliance challenge, as entities majority owned by sanctioned actors are often owned through dynamic, indirect ownership structures. Ownership chains frequently cross jurisdictions, introducing additional complexity for determining ownership. This paper provides a regulatory overview of the 50 Percent Rule, past related enforcement actions, and techniques for navigating complex ownership dynamics. In addition, this paper explores cases falling below 50 percent ownership in which Treasury urges caution.