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Expert Analysis

OFAC Signals Sanctions Diligence Can't Stop At 50% Rule

By Rachel Alpert and Kevin Zhang ( April 23, 2026, 5:14 PM EDT) -- On March 31, the U.S. Department of the Treasury's Office of Foreign Assets Control issued guidance on sham transactions and sanctions evasion. The guidance confirms and formalizes what a series of recent enforcement actions had made clear: While OFAC's long-standing 50% rule is still in place, it is a floor, not a ceiling, to corporate diligence....

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