Understanding OFAC’s 50% Rule and Beneficial Ownership

February 16, 2023 | 09:00 AM – 10:15 AM NYC

Sponsored by

FREE Webinar

CSS Credits: 1.25


75 minutes


  • Benjamin C. Meyer, Senior Associate | KPMG LLP
  • Ruben Pagan, Manager, Trade & Customs | KPMG
  • Elizabeth Shingler, Senior Manager, Trade & Customs | KPMG


Alexander Witt CSS, Sanctions & Export Controls Consultant, ACSS


Thursday, February 16, 2023


  • 09:00 AM – 10:15 AM NYC
  • 02:00 PM – 03:15 PM London
  • 03:00 PM – 04:15 PM Amsterdam


The webinar OFAC’s 50% Rule and Beneficial Ownership will provide participants with the knowledge and tools to understand and apply OFAC’s requirements related to the 50% Rule, which may seem straightforward at first, but is actually quite nuanced.

What you will learn:

  • Did you know that there’s an SDN program where the 50% Rule doesn’t apply?
  • What do you know about Executive Order 13662’s Directive 4’s 33% provision? Does it override the 50% Rule?
  • How do we apply the 50% Rule when it comes to the SSI List?
  • Does it apply when entities are designated under different directives?
  • How can you best situate your organization to contend with the 50% Rule?

We’ll discuss that and much more. Plus, we’ll walk through OFAC’s examples and real-world examples of 50% Rule application.

With additional sanctions against Russia on the horizon, it’s more important than ever that organizations understand the ins and outs of the 50% Rule to ensure both compliance and the ability to transact business that isn’t necessarily prohibited. Join us for a lively discussion about OFAC’s 50% Rule.

During the webinar, participants will have the opportunity to contribute questions online.

Certificate of Attendance:

All active ACSS membership will be able to download the certificate from the Learning Management System (under the achievements tab).


Event Registration


Benjamin C. Meyer

Senior Associate

Ben Meyer is a Senior Associate with KPMG LLP’s Trade & Customs practice located in the Northern Virginia area. Ben has a wealth of experience in the international trade arena, with a specific focus on the aerospace & defense industry. Ben has supported compliance programs in the corporate function, as well as provided consulting support to both large and small clients on a wide array of trade compliance matters throughout his career.

Ruben Pagan

Manager, Trade & Customs

Ruben is a Manager in KPMG’s Trade and Customs practice with extensive experience helping companies understand national and international trade requirements to align their trade functions with business objectives. He has close to 6 years of experience assisting clients with matters ranging from designing large scale end-to-end export control solutions, to the development and implementation of compliance programs, to conducting due diligence related to mergers, acquisitions and divestitures.

Elizabeth Shingler

Senior Manager, Trade & Customs

Elizabeth is a senior manager in KPMG’s Trade & Customs practice in the Richmond office. She has supported clients in managing complex trade matters, including identification and remediation of potential import and export compliance challenges. Further, Elizabeth has assisted multinational companies in performing anti-forced labor risk assessments, as well as identifying and implementing the optimal global trade compliance structure.

Elizabeth is also the Trade & Customs knowledge leader in which she monitors and assesses the impact of regulatory changes to help clients assess the potential impact on their businesses.


Alexander Witt CSS

Sanctions & Export Controls Consultant

Alexander Witt is a Sanctions & Export Control Consultant for the Association of Certified Sanctions Specialists (ACSS). He is an expert in EU, US, and German Sanctions and Export Control Laws and Regulations. Previously Alexander worked as a Sanctions & Export Control Consultant at Full Circle Compliance and as an Export Compliance Officer at Fujifilm Europe in the Netherlands.

Customer Testimonials

“I really appreciated the detail and references on the slides, very helpful”.

Scott Kinney, CAMS

Compliance Manager Global Sanctions Group, Wells Fargo Bank, N.A.

“Great job. Very informative”.

Brianna Long

Senior Compliance Analyst Compliance and Risk Investigations and Analysis, Convera