SCREENING CHALLENGES ARISING FROM LACK OF DATA

Researching Ownership and Control for Non-Listed Entities that May Fall Under the 50% Rule

December 6, 2018 2:15pm

Daniel Alexander
Managing Director, Deputy Global Sanctions Officer
Charles Schwab (San Francisco, CA)

Neha Jain
Head of Global Sanctions Advisory-Director
MUFG (New York, NY)

Stephanie Norris
ITC Manager, Contracts & Screening
GE (Washington, DC)

Alicia M. Novak
Director, Global Sanctions
Fidelity Investments (Boston, MA)

  • Why 50% Rule research is more important and complex than ever
  • Methods for determining entities subject to the 50% Rule in a time of rapidly changing sanctions regulations
  • Obtaining senior management buy-in and business support
  • Strategies for evaluating company ownership structures and monitoring the future state
  • How much research is enough? Is it necessary to hire a vendor? When do I need to file a report with OFAC?