A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength.
Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations.
Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On August 13, OFAC broadened the scope of its sanctions programs
by revising a rule on the ownership of entities by targeted
individuals. Effective upon publication, the new guidance on the
so-called "50 percent rule" states that an entity is
subject to OFAC sanctions if any combination of sanctioned
individuals collectively owns at least 50 percent of it. For
instance, if Blocked Person X owns 25 percent of Entity A and
Blocked Person Y owns 35 percent of Entity A, then Entity A is
blocked, because Entity A is owned 50 percent or more in the
aggregate by blocked persons. Previously, the 50 percent rule
required a single sanctioned person to own 50 percent or more of an
entity for it also to be subject to sanctions. The change brings US
sanctions into alignment with EU sanctions, which also aggregate
the interests of blocked persons.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
