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 countries." The list is not limited to state actors and contains non-country specific individuals, groups, and entities. Currently, the list contains approximately 6,400 companies and individuals.

Persons can be added to the SDN list in several ways. In some cases, the President issues an executive order directing the Secretary of the Treasury, in consultation with the Secretary of State, to identify individuals or entities that should be added to the list. In other cases, the President directly identifies individuals or entities to designate as SDNS. Once on the list, U.S. persons and businesses are prohibited from obtaining goods, services, or technology from SDNs, or otherwise transacting with them. This prohibition extends to business conducted through third-party intermediaries. Indeed, "[i]nclusion on the SDN List generally prohibits U.S. banks from maintaining accounts for those listed and U.S persons could face civil or criminal penalties for engaging in business dealing with them."

Under Treasury Department guidance, a sanctioned individual may own a minority interest in a company and still access the U.S. financial system. OFAC's "50 percent rule," states that "any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person." This is significant because an entity meeting this standard incurs SDN restrictions even if the entity itself is not named on the SDN list.