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gateOFAC — US Sanctions Primacy Gate
// IMMO.QUICK · GATEOFAC · SDN LIST · 50% RULE · SECONDARY SANCTIONS

One hit, and nothing overrides it.

gateOFAC forensically seals that a transaction passes four clusters, SDN list matching, sectoral sanctions, the 50 percent ownership rule, and secondary sanctions exposure, before it is approved. The forensic backbone behind the sanctions primacy rule in gateTransatlanticConflict.

Request Access → See the architecture
In one sentence: gateOFAC checks every transaction against US sanctions lists and the 50 percent ownership rule before approval, regardless of what every other gate concludes.
✓ RELEVANT IF...
  • You process transactions with a US dollar nexus or US person involvement
  • You need to check the 50 percent ownership rule for layered ownership structures
✕ NOT RELEVANT IF...
  • You expect OFAC to automatically recognise the result as a licence or exemption
  • No US person nexus, US dollar clearing, or US sanctions list is involved
// 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
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