Exam CGSS Topic 4 Question 84 Discussion

Actual exam question for ACAMS's CGSS exam
Question #: 84
Topic #: 4
ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?

Suggested Answer: D Vote an answer

OFAC's 50 Percent Rule requires aggregation of ownership by SDNs and entities owned 50% or more by SDNs.
Ownership breakdown:
* Entity X (SDN) → 30%
* Entity Y (owned 80% by an SDN) → treated as an SDN → contributes 25%
* Total SDN-derived ownership = 30% + 25% = 55%
Since aggregate SDN ownership exceeds 50%, ABC Industries is automatically considered a blocked entity, even though Entity Z is not sanctioned.
Options B and C are incorrect because explicit listing is not required-ownership triggers blocking. Option A is incorrect because one SDN at 30% alone is insufficient, but combined ownership is.
Reference:
OFAC 50 Percent Rule (aggregation principle).
Treatment of entities majority-owned by SDNs as SDNs for ownership calculations.

by Colby at Oct 14, 2026, 06:19 PM

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