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§ 546.412 Entities of which one or more blocked persons is a member, leader, official, senior executive officer, or otherwise exercises control.
(a) The property and interests in property of an entity, including any political subdivision, agency, or instrumentality of a governmental entity, are not blocked solely because one or more persons whose property and interests in property are blocked pursuant to § 546.201 is a member, leader, official, senior executive officer, or otherwise exercises control.
Note 1 to paragraph (a). See § 546.411 concerning the blocked status of property and interests in property of an entity that is directly or indirectly owned, whether individually or in the aggregate, 50 percent or more by one or more persons whose property and interests in property are blocked pursuant to § 546.201.
(b) For example, U.S. persons may not, except as authorized or exempt pursuant to this...
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1) 546.412 is the first codification of OFAC's longstanding practice concerning dealings with entities controlled, but not owned, by blocked persons. Compare FAQ # 398 ("OFAC’s 50 Percent Rule speaks only to ownership and not to control. An entity that is controlled (but not owned 50 percent or more) by one or more blocked persons is not considered automatically blocked pursuant to OFAC’s 50 Percent Rule").
The "routine interactions" portion of this interpretive provision is a version of the guidance found at FAQ # 840, FAQ # 993, FAQ # 1145, and Guidance for the Provision of Humanitarian Assistance to the Palestinian People all of which state (with slight grammatical differences) that "engaging in a routine interaction with an agency in which a blocked individual is an official, but that does not involve the blocked individual...