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50% rule in sanctions screening and when a counterparty counts as listed

What the EM System and Inter Rao Lietuva judgments and OFSI's Citibank penalty mean for counterparty checks under EU, UK and US rules

Aušra Šablinskienė
Sanctions expert, Lithuania
Andrius Košel
Attorney-at-law, Counsel, professional law partnership NOOR legal, Lithuania
Published 27 Sep 2026
50% rule in sanctions screening and when a counterparty counts as listed
Adobe Stock
Topic spotlight

Whether an unlisted company is caught by the asset freeze applicable to its shareholder was tested twice in 2026. In EM System, a case under the Belarus regime, the Court of Justice confirmed a rebuttable control presumption at exactly 50%. In Inter Rao Lietuva, it required objective and sufficiently solid evidence where control is alleged without a sufficient ownership basis. OFSI's £4.7 million Citibank penalty shows the operational cost of freezing too late. This article explains what those developments mean for counterparty screening, how the UK and US rules differ from the EU framework, and what the file should contain.

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EU sanctions: where listed and what consequences

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Territorial import bans: the ban set by origin, and the proof that lifts it

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What a territorial import ban is, the EU bans in force, and how goods clear one - by proving, in the right form, that they do not originate in the…

Sanctions
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Exporter of dual-use items: a definition that changes with the regulation

03 Aug 2026

Who counts as the exporter differs across the customs code, the dual-use regulation and the anti-torture regulation - and naming the wrong one can leave an export unlicensed.

Restrictions
Sanctions
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EU sanctions: the goods they restrict, and the national rules on top

03 Aug 2026

How EU sanctions restrict goods by commodity code, the national measures member states add on top, who must comply, and the penalties - the full EU picture for traders.

Sanctions
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EU sanctioned persons: who you cannot pay, supply or trade with

03 Aug 2026

Who is an EU sanctioned person, who designates them, and what is prohibited - including the 50% ownership rule that catches companies on no list, and the penalties.

Sanctions
How can AI simplify compliance with international sanctions regimes?

How can AI simplify compliance with international sanctions regimes?

Aušra Šablinskienė
Aušra Šablinskienė
29 Jan 2026

In this article, we focus on the constantly evolving and highly complex legal landscape of EU sanctions imposed on third countries. We explore whether artificial intelligence (AI) can enable more…

Digitalisation
Sanctions
Explainer
Customs Compliance & Risk Management, Issue 40, August / September 2026
Aušra Šablinskienė
Andrius Košel
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