Anytime an SDN individual or entity has any interest in a company, the possibility of complications substantially increases. If you are conducting due diligence to determine an SDN’s interest in a company, it is important to properly assess their ownership stake and direct or indirect control over the entity. Companies may err on the side of caution in these instances and subsequently refuse to do business with a company strongly associated with an SDN person or entity. OFAC itself states that these persons may be subject to being later placed on the SDN List. The actual legal rule that applies in this instance is OFAC’s 50% rule.