Walks a synthetic ownership graph; computes aggregate beneficial ownership from listed entities; applies OFAC, EU, and BIS Affiliates Rule (in force 29 Sep 2025) 50%-thresholds to determine constructively-blocked entities. Pure graph math — synthetic entities only. Part of the sanctions-ownership chain.
OFAC 50%-Rule · EU Reg. 833/2014BIS Affiliates Rule · 15 CFR §744BIS in force 29 Sep 2025 · EU 20th 23 Apr 2026
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Ownership Graph
Thresholds
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Blocked Entities
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Listed Entities
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Total Entities
Entity Verdicts
Entity ID
OFAC %
EU %
BIS %
Blocked Under
Constructively Blocked
Controlling Path
Compliance Flags
Regulatory Notes — verify against current official sources
BIS Affiliates Rule (15 CFR §744, in force 29 Sep 2025): Entity List restrictions auto-extend to affiliates that are ≥50% in aggregate owned by a listed entity. · OFAC 50% Rule: entities ≥50% aggregate-owned by one or more SDNs are constructively blocked even if not individually named. · EU 20th Sanctions Package in force 23 Apr 2026 — anti-circumvention scope widened. · EDUCATIONAL: synthetic entities only — outputs are decision-support drafts.