The buyer is an LLC. Who is behind it?

Who the statute reaches

Individuals domiciled in a designated country who are not United States citizens or lawful permanent residents. Governments and government-linked entities of a designated country. Companies headquartered in, or controlled by, any of the above. The designated countries today are China, Iran, North Korea, and Russia. The Governor may add countries. Verify the current list before you rely on it.

The control tests in the proposed rules

The proposed Chapter 67 rules treat control as direct or indirect power over an entity's management, policies, or its acquisition of Texas real property. ParcelClear's questionnaire asks for general partners, managing members, holders of ten percent or more, and executive officers, and lets the reviewer add anyone else the documents show. Those tests come from the proposed rules and the statute's definitions. They are not adopted. Verify against the rule text as adopted.

Why the tree is the record

If a control person turns out to be a prohibited person, the question later will be whether anyone looked. A tree with names, roles, and an attestation that it is complete, dated before closing, answers that question. A blank answers it the other way.

What a record shows for an entity buyer

The entity's answers, every control person by name and role, the reviewer's attestation that the tree is complete to the best of their knowledge from the documents in the file, an OFAC screen of every name, the rule result, and the hash. If the tree is not attested, the result is HOLD. The record never shows NO RULE TRIGGERED on an incomplete tree.

What it does not do

It does not verify ownership documents. It does not check corporate registries. It records what the documents in your file say and what the sanctions lists say about those names. The professional decides what to do with a HOLD.