Does the 50 percent rule also apply in the EU?

Yes. Under its Best Practices for implementing restrictive measures, the EU applies the principle that companies owned or controlled by a listed person or company at a level of 50 percent or more are also treated as blocked. The equivalent in US law is the OFAC 50 Percent Rule.

Are the holdings of several listed shareholders added together?

Yes. If several listed people or companies together hold 50 percent or more, the target company is also treated as blocked, even if no individual shareholder reaches the threshold.

What happens where there is control below 50 percent?

Control can exist without a majority shareholding, for example through a majority of voting rights, the appointment of governing bodies or another form of dominant influence. The making-available prohibition also applies in these cases.

Does Am I Compliant replace legal advice?

No. The screening result is a risk indicator and does not constitute legal advice. The legal assessment and decision remain your responsibility.

Topic · 50 percent rule

The 50 percent rule in sanctions

Last updated: 21 August 2026

The 50 percent rule means that if a sanctioned person or company owns 50 percent or more of another company, or controls it, that company is also treated as blocked, even if it does not appear on a list. The holdings of several listed shareholders are added together. Affiliated companies therefore also need to be screened.

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What does the 50 percent rule mean?

The rule applies when a listed person or company directly or indirectly holds 50 percent or more of another company. The holdings of several listed people are added together. In the EU, the basis is the EU Best Practices for implementing restrictive measures; in US law, it is the OFAC 50 Percent Rule.

What do ownership and control mean?

Ownership refers to the size of a shareholding. Control may also exist below 50 percent, for example through a majority of voting rights, the right to appoint governing bodies or another form of dominant influence. The company concerned is then also subject to the making-available prohibition.

Why is screening only the direct business partner insufficient?

The making-available prohibition also covers indirect benefits. If a listed person benefits economically through an affiliated company, providing goods or services to that company is also prohibited. Affiliated companies must therefore be included in screening.

How do I screen affiliated companies with Am I Compliant?

Enter the business partner and any affiliated people and companies known to you, or upload a document. The system screens this information against 20 official sanctions, PEP and crime lists from 18 jurisdictions and provides an audit-proof PDF with a verification URL for your records.

What are the penalties for a violation?

A breach of sanctions and the making-available prohibition is a criminal offence under Section 18(1) of the German Foreign Trade Act (AWG), punishable by three months to five years in prison, or six months to ten years in particularly serious cases (Section 18(6a) AWG). Companies may additionally face a corporate fine of up to €40 million (Section 19(7) AWG). Managing directors who breach their supervisory duties face personal fines of up to €1 million (Section 130(3) of the German Administrative Offences Act, OWiG).

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Screening against 20 official sanctions and PEP lists from 18 jurisdictions, with an audit-proof PDF.