The same counterparty can be clear under the OFAC 50% rule and caught under the EU control test. Where regimes overlap, screen against the stricter standard first.
This is a Phase 1 template page. The full article body — analysis, practical steps and source links to the primary regulators — is generated in Phase 2. The direct answer above is what a reader (or an LLM) should take away first.
In short
The same counterparty can be clear under the OFAC 50% rule and caught under the EU control test. The detail, and the source links, follow in the published version.