{"kind":"evidence_file","company":{"id":"97380127-927c-4af9-b1d4-75c574579fe1","name":"ALPA TRADING FZCO","mergedInto":null},"asOf":"2026-10-26T09:08:14.581Z","asOfBasis":"instant","generatedAt":"2026-10-27T13:01:45.273Z","claims":[{"predicate":"identifier","value":"reg_number:11701069","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"17205","observedAt":"2026-08-28T11:58:22.719Z","confirmedAt":"2026-10-08T15:03:26.471Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"identifier","value":"reg_number:11701069","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"17205","observedAt":"2026-09-13T15:02:13.235Z","confirmedAt":"2026-10-26T05:00:16.057Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"name","value":"alpa trading fzco","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"17205","observedAt":"2026-08-28T11:58:22.705Z","confirmedAt":"2026-10-08T15:03:26.454Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"name","value":"alpa trading fzco","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"17205","observedAt":"2026-09-13T15:02:13.223Z","confirmedAt":"2026-10-26T05:00:16.039Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"primary_country","value":"AE","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"17205","observedAt":"2026-08-28T11:58:22.708Z","confirmedAt":"2026-10-08T15:03:26.458Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"primary_country","value":"AE","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"17205","observedAt":"2026-09-13T15:02:13.227Z","confirmedAt":"2026-10-26T05:00:16.044Z","validFrom":null,"validTo":null,"supersededLater":null}],"listings":[{"listingId":"17205","regime":"UK OFSI","program":"Global Irregular Migration and Trafficking in Persons","state":"in_force","stateSince":"2026-08-28T11:58:22.726Z","recordedAt":"2026-08-28T11:58:22.726Z","designatedAt":"2025-10-22T00:00:00.000Z","validTo":null,"legalBasis":"The Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025","reason":"The Secretary of State considers that there are reasonable grounds to suspect ALPA TRADING FZCO is an involved person under the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 (\"the Regulations\") on the basis of the following grounds: \n(1)\tIt is or has been involved in a relevant activity, namely people smuggling, by facilitating the unlawful arrival in a country of individuals who are not a national of that country or permanently resident in it with a view to obtaining any gain or benefit. Specifically, it has purchased equipment, namely engines, motors and spare parts, from East Asia for the purpose of facilitating the irregular arrival of migrants across the English Channel into the United Kingdom.\n(2)\tIt is or has been involved in a relevant activity, namely people smuggling, by profiting financially from the unlawful arrival in a country of individuals who are not a national of that country or permanently resident in it. Specifically, it has profited from the supply of equipment, namely engines, motors and spare parts, from East Asia for the purpose of facilitating the irregular arrival of migrants across the English Channel into the United Kingdom.\n(3) It is or has been involved in a relevant activity, namely people smuggling, by facilitating \nthe unlawful arrival in a country of individuals who are not a national of that country or permanently resident in it with a view to obtaining any gain or benefit. Specifically, it has provided goods, namely engines, motors and spare parts, from East Asia that could contribute to the irregular arrival of migrants across the English Channel into the United Kingdom.","sanctionType":"Asset freeze, Director Disqualification Sanction","documentUrl":null,"assertedBy":["UK OFSI Consolidated List","UK Sanctions List (FCDO)"],"sourceNow":"UK Sanctions List (FCDO)"}],"ownership":[],"lists":[{"source":"EU Consolidated Sanctions List","readAt":"2026-10-26T04:33:16.293Z","recordsRead":6269,"publishedAt":"2026-10-23T15:05:43.888Z","publishedAtBasis":"stated_in_file","publisherVersion":"globalFileId 185833","publisherRecordCount":null,"daysOldWhenRead":3,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 23 October 2026, 3 days before it was read."},{"source":"Malaysia BNM financial consumer alert list","readAt":"2026-10-19T11:00:24.650Z","recordsRead":588,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Malaysia SC investor alert list","readAt":"2026-10-26T09:01:45.100Z","recordsRead":1803,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 26 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"OFAC SDN","readAt":"2026-10-26T04:13:22.021Z","recordsRead":17561,"publishedAt":"2026-10-21T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":19471,"daysOldWhenRead":5,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 21 October 2026, 5 days before it was read."},{"source":"Slovenia KPK business restrictions","readAt":"2026-10-15T11:03:08.201Z","recordsRead":4351,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 15 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Switzerland SECO Sanctions List","readAt":"2026-10-26T09:03:48.311Z","recordsRead":7036,"publishedAt":"2026-10-20T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":6,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 20 October 2026, 6 days before it was read."},{"source":"Türkiye MASAK asset freezes","readAt":"2026-10-22T12:00:24.158Z","recordsRead":2304,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"UK OFSI Consolidated List","readAt":"2026-10-08T15:05:56.072Z","recordsRead":5120,"publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":127,"detail":"Newest designation in the file: 2025-12-19.","statement":"Read on 8 October 2026. The file carries no date of its own; its newest record is dated 3 June 2026, 127 days before it was read. Newest designation in the file: 2025-12-19."},{"source":"UK Sanctions List (FCDO)","readAt":"2026-10-26T05:02:22.241Z","recordsRead":5705,"publishedAt":"2026-10-16T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":10,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 16 October 2026, 10 days before it was read."},{"source":"US CBP forced-labour orders (WRO & Findings)","readAt":"2026-10-20T13:00:21.679Z","recordsRead":63,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"US Consolidated Screening List","readAt":"2026-10-26T07:03:39.603Z","recordsRead":6479,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 26 October 2026. No date from the publisher is read for this file, so its age is not known here."}],"reading":{"assessmentId":"98ca10c7-4db1-4b65-b73d-c9dbf6e152dd","takenAt":"2026-09-06T17:08:51.236Z","methodology":"v4","level":"medium","overall":60,"digest":"b4df3796ee022ace7cf02299340a2f837dbddb2b","coverage":{"dimensions":[{"counts":{"found":1,"not_found":9},"sources":[{"name":"EU Consolidated Sanctions List","status":"not_found","attemptedAt":"2026-08-28T15:36:29.864Z"},{"name":"Malaysia BNM financial consumer alert list","status":"not_found","attemptedAt":"2026-08-31T15:51:29.907Z"},{"name":"Malaysia SC investor alert list","status":"not_found","attemptedAt":"2026-08-31T09:00:45.899Z"},{"name":"OFAC SDN","status":"not_found","attemptedAt":"2026-08-28T16:28:26.648Z"},{"name":"Slovenia KPK business restrictions","status":"not_found","attemptedAt":"2026-09-03T11:01:50.151Z"},{"name":"Switzerland SECO Sanctions List","status":"not_found","attemptedAt":"2026-08-31T09:01:35.798Z"},{"name":"Türkiye MASAK asset freezes","status":"not_found","attemptedAt":"2026-09-03T12:00:11.768Z"},{"name":"UK OFSI Consolidated List","status":"found","attemptedAt":"2026-08-28T15:20:44.438Z"},{"name":"US CBP forced-labour orders (WRO & Findings)","status":"not_found","attemptedAt":"2026-09-01T13:00:04.513Z"},{"name":"US Consolidated Screening List","status":"not_found","attemptedAt":"2026-08-28T15:54:36.663Z"}],"dimension":"sanctions"},{"counts":{"not_found":4},"sources":[{"name":"Malaysia BNM financial consumer alert list","status":"not_found","attemptedAt":"2026-08-31T15:51:36.262Z"},{"name":"Malaysia SC investor alert list","status":"not_found","attemptedAt":"2026-08-31T09:00:52.349Z"},{"name":"Slovenia KPK business restrictions","status":"not_found","attemptedAt":"2026-09-03T11:01:57.777Z"},{"name":"US CBP forced-labour orders (WRO & Findings)","status":"not_found","attemptedAt":"2026-09-01T13:00:11.700Z"}],"dimension":"debarment"}],"jurisdictions":[{"gap":"No company register for this jurisdiction has been connected to this system, and none has been examined.","reasons":["registered here","holds a register number issued here"],"countryId":"AE","registers":[]}]},"ownership":null},"limits":["Whether each listing was in force is rebuilt from what was recorded here: when it was first read, when a source stopped or resumed carrying it, and when its published term ended. A listing in force at an authority before this system first read it is shown from that first read.","No ownership verdict is kept for this company. Verdicts are kept for companies registered where shareholders are read here: Estonia, Latvia and Poland."]}