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gateOFAC — US Sanctions Primacy Gate
// The problem

An SDN hit is not a negotiating position.

Unlike the four collision patterns in gateTransatlanticConflict, a direct OFAC hit admits no resolution in favour of another legal order. gateOFAC is the check layer that actually technically enforces that primacy.

The 50 percent rule applies even when layered
If sanctioned persons cumulatively hold at least 50 percent of a holding company together, the holding company itself is treated as sanctioned, even if no single person individually reaches the threshold.
// Architecture

4 clusters, checked sequentially.

Every cluster is dispositive (material_block_mode: true), a hit blocks bindingly, not merely for documentation.

CLUSTER 1
SDN List Matching
Screens all transaction parties in real time against the Specially Designated Nationals List.
sdn_list_hit · fuzzy_match_score
CLUSTER 2
Sectoral Sanctions
Checks the Sectoral Sanctions Identifications List for financing and technology restrictions under the relevant directives.
ssi_list_hit · directive_type
CLUSTER 3
50 Percent Ownership Rule
Calculates the cumulative ownership stake of sanctioned persons in the target entity, even across multiple ownership layers.
cumulative_sanctioned_ownership_pct
CLUSTER 4
Secondary Sanctions Exposure
Checks whether the transaction triggers third-party sanctions risk under the secondary sanctions regimes.
secondary_sanctions_risk_flag
No case, no doubt
Every cluster returns its own sealed result. A single hit in an active cluster is enough to block the overall action.
// Test results

Two tested scenarios.

All values on this page are fictional test data and serve only to illustrate the gate logic.

Scenario C1C2C3C4 Verdict Latency
Payment to counterparty with no list hit, ownership structure below 50%, no secondary riskPASSPASSPASSPASSOFAC_SEALED298ms
Holding with cumulative 62% sanctioned ownership across two layersPASSPASSFAILnot evaluatedBLOCK_OF3_FIFTY_PERCENT_RULE_TRIGGERED341ms
Cryptographic chain continuation
Every test produces a deterministic receipt_id, an input_snapshot_hash, an HMAC-SHA256 signature, and a merkle_link to the previous receipt. Persistence occurs in the gateOFACReceipt entity with a 10-year retention period.
// Clarification

What gateOFAC is not.

  • Not automatic recognition by OFAC. The gate delivers a cryptographic proof, not a licence and not an exemption.
  • Not a replacement for an OFAC licence application. If the gate blocks, that does not replace a formal exemption request to OFAC itself.

For institutions with US dollar exposure that want to make sanctions freedom provable.

Request Access → access@immoquick.eu
GATE CATALOG · REGULATORY DETERMINATION DOMAIN

gateOFAC

gateOFAC determines encoded sanctions-list, party, ownership, nexus and transaction conditions for a defined matter. The gate contributes a bound regulatory determination state; it creates neither regulatory authority nor Execution Permission.

DOMAIN_DETERMINATION_ONLY = true · EXECUTION_AUTHORITY = false · EXECUTION_PERMISSION = false
Explore Gate Catalog →Execution Rights →
gateOFAC regulatory determination domain
AUTHORITY BOUNDARY

SANCTIONS STATE IS NOT SANCTIONS AUTHORITY.

CAN

  • deterministically evaluate encoded regulatory conditions
  • bind determinations to source, scope, time and input state
  • surface missing, expired or conflicting regulatory dependencies
  • produce attributable evidence for the concrete determination

CANNOT

  • replace a regulator, supervisor, court or competent institution
  • create legal or regulatory authority through score, consensus, AI or administration
  • turn a gate PASS into an Execution Right on its own
  • mint an ExecutionCapabilityToken on its own
REGULATORY STATE

Regulatory determination is evidence. Not regulatory authority.

SOURCE

Authoritative source

The relevant rule must originate outside the system from a legitimate normative or institutional source.

SCOPE

Defined matter

The determination is limited to the encoded subject, entity, transaction or operation under review.

TIME

Point-in-time state

Effective dates, transition periods, expiry and version state remain explicit.

INPUT

Canonical input

A reproducible determination requires a defined canonical input state.

DEPENDENCY

Dependencies

Missing or contradictory dependencies remain visible rather than being converted into invented permission.

EVIDENCE

Bound evidence

The resulting state can be bound to source, input, scope and time for later verification.

RELATED DETERMINATION DOMAINS

Regulatory domains compose. They do not confer authority on one another.

gateAMLgateUSExportControlsgateUSLawsgateLegalConflict

Only scope-relevant determinations become dependencies in Execution Rights resolution. The links shown are not a universally mandatory sequence.

EXECUTION RIGHTS

Five dimensions. Regulatory state can inform them; no gate replaces them.

AAUTHORITY
RRULE
JJURISDICTION
TTIME
DDEPENDENCY
ALL FIVE REQUIRED DIMENSIONS VALID → VALID EXECUTION RIGHT · ANY REQUIRED DIMENSION ABSENT → NO VALID EXECUTION RIGHT → NO CAPABILITY → NO EXECUTION
INVARIANT

A regulatory PASS is a determination. Never a permission by itself.

AUTHORITY → DETERMINATION → EXECUTION RIGHTS → CAPABILITY OR NONE → EXECUTION OR NONE → EVIDENCE

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