On Aug. 13, 2014 the Treasury Department’s Office of Foreign Asset Control (OFAC) issued new guidance that expands the due diligence responsibilities for charities and others involved in transactions by banning transactions with entities that are not on OFAC’s Specially Designated Nationals and Blocked Persons list but where the ownership interests of blocked persons adds up to 50 percent or more. Charities do not have “owners” but this could affect organizations contracting with vendors as part of program implementation. The 50 percent rule does not apply to control (as opposed to aggregated ownership). OFAC said when there is a question of control by listed persons “companies should proceed with caution…” OFAC issued Frequently Asked Questions to provide clarification of the guidance. Legal experts called the change “significant” and described the result as “shadow” SDNs.