Worked case · Reference condition · 12 figures

Reproducible graph determination

Make the calculation auditable

Figure 01 / 12

Direct holdings in the ownership graph

Direct holdings in the ownership graph — Reproducible graph determination. Percent ownership; effective date fixed for this case. Exact values are in the figure data below.
Percent ownership; effective date fixed for this case

The directed edges are documented ownership interests in this synthetic U.S. OFAC example. Owners X and Y are assumed blocked. The graph contains no cross-holdings, trusts, nominee arrangements, or conflicting share classes; those would require additional analysis.

Figure data and text version
OwnerEntityStake
Blocked owner XIntermediate A32%
Blocked owner YIntermediate A13%
Intermediate ACustomer B80%
Other ownersCustomer B20%

The reviewer needs to reconstruct which edges, dates, identities, and rule version produced a conclusion. Numeric output alone cannot explain an ownership assessment.

The reference case starts with the stated population and a functioning evidence path. The owner is ownership engine owner.

All amounts, rates, capacity limits, and outcomes in this case are synthetic. The three conditions are separate assumptions for comparison. A better result in the response condition is not measured proof that the proposed control causes that improvement. The figures expose the calculation and its limits; a real deployment needs its own evidence.

Read the result

Assumed blocked owners hold 32% and 13% of Intermediate A. Their aggregate is 45%. A then owns 80% of Customer B. The worked determination is: Not shown blocked by this ownership calculation alone. The simple economic product of 36.00% is retained only to show why multiplication and rule-specific status propagation are different operations.

Model inputs and calculated values

Inputs below are the case-specific values. Each figure states the condition-specific assumptions and units used in its calculation. Calculated values are rounded for display.

InputValue
stakeA32
stakeB13
childStake80
Calculated valueResult
stakeA32
stakeB13
aggregate45
childStake80
knowntrue
blockedAfalse
blockedBfalse
naiveProduct36
Figure 02 / 12

Aggregate the relevant direct interests

Aggregate the relevant direct interests — Reproducible graph determination. Percent; totals 100. Exact values are in the figure data below.
Percent; totals 100

Assumed blocked owners X and Y hold 32% and 13% of Intermediate A, for 45% in aggregate. Other interests total 55%. The chart counts each direct holding once and uses one common ownership basis.

Figure data and text version
HoldingPercent
Blocked owner X32
Blocked owner Y13
Other owners55
Figure 03 / 12

An adjacency matrix preserves edge meaning

An adjacency matrix preserves edge meaning — Reproducible graph determination. Percent; columns total 100. Exact values are in the figure data below.
Percent; columns total 100

Rows identify owners and columns identify entities. Each nonzero cell is one direct interest from the graph. A matrix can help detect duplicated edges and inconsistent totals, but it cannot resolve a missing or unreliable ownership fact.

Figure data and text version
OwnerIntermediate ACustomer B
Blocked owner X320
Blocked owner Y130
Intermediate A080
Other owners5520
Figure 04 / 12

Status propagates through qualifying entities

Status propagates through qualifying entities — Reproducible graph determination. Simplified application of the stated ownership rule. Exact values are in the figure data below.
Simplified application of the stated ownership rule

Intermediate A has 45% aggregate ownership by assumed blocked persons. In the known-data calculation, its status is not established as blocked by this test. Its 80% holding in Customer B is then evaluated in that capacity. Incomplete evidence prevents a final conclusion.

Figure data and text version
StepResult
Identify blocked rootsX and Y are assumed blocked in this example
Evaluate Intermediate A32% + 13% = 45%
Evaluate Customer BIntermediate A holds 80%
Record determinationNot shown blocked by this ownership calculation alone
Figure 05 / 12

Economic multiplication is a different calculation

Economic multiplication is a different calculation — Reproducible graph determination. Percent and legal-status concepts kept separate. Exact values are in the figure data below.
Percent and legal-status concepts kept separate

A simple product gives 36.00% economic look-through interest. That number does not replace OFAC status propagation through an entity that is itself blocked under the 50 Percent Rule. The rule-specific analysis must retain both the graph and the intermediate determinations.

Figure data and text version
CalculationResultMeaning
Aggregate root interest in A45%Relevant direct holdings
A interest in B80%Direct holding by A
Simple economic product36.00%Not the status-propagation algorithm
B determinationNot shown blocked by this ownership calculation aloneDepends on qualifying blocked ownership and reliable facts
Figure 06 / 12

The ownership threshold is a discontinuity

The ownership threshold is a discontinuity — Reproducible graph determination. Percent; 0/100 indicator is not a risk probability. Exact values are in the figure data below.
Percent; 0/100 indicator is not a risk probability

The plot varies owner Y’s stake while holding X at 32%. The status indicator changes when their aggregate reaches 50%. An indicator of 100 means the stated test is met; it is not a probability or a severity score. Other restrictions can still apply below that point. Horizontal positions are the labeled observations or scenarios; equal spacing does not imply equal numerical increments.

Figure data and text version
Y stakeAggregate %Test indicator
0%320
10%420
18%50100
20%52100
30%62100
40%72100
50%82100
Figure 07 / 12

Every edge needs dated evidence

Every edge needs dated evidence — Reproducible graph determination. Illustrative evidence register. Exact values are in the figure data below.
Illustrative evidence register

An ownership result is only as defensible as its inputs. Keep the document, effective date, retrieval date, ownership basis, and reviewer attached to the edge. A recent download of an old filing does not make the underlying ownership current.

Figure data and text version
EdgeEvidence stateRequired interpretation
X → ACorporate filing, datedConfirm identity and ownership basis
Y → AVerified case recordDo not replace unknown with zero
A → BOwnership registerConfirm effective date and share class
Other ownersResidual interestA residual total is not proof of their identities
Figure 08 / 12

A repeated record is not a second holding

A repeated record is not a second holding — Reproducible graph determination. Percent; invalid method shown for diagnosis. Exact values are in the figure data below.
Percent; invalid method shown for diagnosis

If X’s 32% edge appears twice in a data feed, naive addition produces 77% instead of the supported 45%. Deduplicate by the underlying ownership fact and effective interval, not merely by a convenient text label.

Figure data and text version
Aggregation methodPercent
Supported X plus Y45
X accidentally counted twice77
Duplicate contribution32
Figure 09 / 12

Control and ownership are separate relationships

Control and ownership are separate relationships — Reproducible graph determination. Typed relationships; only ownership enters this percentage calculation. Exact values are in the figure data below.
Typed relationships; only ownership enters this percentage calculation

The management edge is deliberately different from an ownership edge. Control by a blocked person can raise separate concerns, but it should not be silently converted into a percentage within this ownership formula. The appropriate legal review considers the actual program and facts.

Figure data and text version
FromToRelationship
Manager MCustomer BManagement control
Intermediate ACustomer B80% ownership
Blocked owner XIntermediate A32% ownership
Figure 10 / 12

Unknown is a distinct evidence state

Unknown is a distinct evidence state — Reproducible graph determination. State contract. Exact values are in the figure data below.
State contract

The current determination is: Not shown blocked by this ownership calculation alone. A screening engine should be able to return unresolved evidence without forcing a false clear or a false exact percentage. Operational handling must follow the institution’s approved procedure and applicable obligations.

Figure data and text version
Evidence stateMachine representationImplication
Known stake13%Use the supported effective-date value
Missing stakenullDo not coerce to zero
Conflicting documentsconflictPreserve both and escalate
Determinationnot-establishedRecord scope and limitations
Figure 11 / 12

A change in facts starts another assessment

A change in facts starts another assessment — Reproducible graph determination. Illustrative change history. Exact values are in the figure data below.
Illustrative change history

A prior ownership review is a dated conclusion. New filings, a transfer of shares, a list update, or a correction to entity identity can change the relevant facts. The event log should preserve the old conclusion while recording the basis for the new one.

Figure data and text version
EventRecordEffect
Prior assessmentGraph version 1Conclusion tied to earlier facts
New ownership evidenceA duplicated edge changes the total while the stored result omits its explanation path.Rebuild affected paths
Identity resolutionEntity IDs and source recordAvoid merging unrelated owners
New assessmentGraph version 2Record determination and reviewer
Figure 12 / 12

A reproducible determination record

A reproducible determination record — Reproducible graph determination. Illustrative audit record. Exact values are in the figure data below.
Illustrative audit record

The final record contains enough information to explain the result without relying on the diagram alone. A complete implementation also needs validation for cycles, over-allocated shares, duplicate legal interests, and structures outside the approved method.

Figure data and text version
FieldValue
customer_refReproducible graph determination
rule_scopeU.S. OFAC 50 Percent Rule illustration
aggregate_blocked_ownership_A45%
A_ownership_B80%
input_completetrue
determinationNot shown blocked by this ownership calculation alone

Connect the result to the system

Validate the graph and retain the supporting edge set and each intermediate result.

Check the population, evidence, permitted action, and actual effect together. A balanced calculation can still use the wrong population; a successful response can still leave an unknown financial outcome. The case’s numerical result applies only to its stated assumptions.

Sources and further reading

The chapter sources support the concepts and scope. They do not prescribe the synthetic model rates.

  1. OFAC FAQ 401: indirect ownership and the 50 Percent Rule
  2. OFAC FAQ 398: ownership and control