{"id":"00220d7f-8cd4-45ea-b2de-a258d651c2e0","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:33:36.639Z","confirmedAt":"2026-10-27T11:33:28.915Z","supersededAt":null,"company":{"id":"95d2a4ae-8f09-432c-9f2d-345c84d4b8c6","name":"Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji)"},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["Natural-person holders are compared with designated persons by name only. A match is reported and never counted, because the registers publish no identifier that could confirm it."],"breaks":{"first":[{"share":null,"detail":"The KRS struck this company off the register on 03.09.2024, so it publishes no current holders for it.","reason":"not_found_in_register","company":{"name":"Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji)","number":"0000417343","countryId":"PL"},"holderName":null}],"total":1,"byReason":{"not_found_in_register":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-13T14:47:39.470Z","source":"OFAC SDN","publishedAt":"2026-09-10T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":null,"publishedAtBasis":null}]},"caveats":["The rule speaks only to ownership. An entity controlled by a blocked person without being owned 50% or more is not blocked by it, though it may be designated in its own right.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji) (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000417343","entityId":"95d2a4ae-8f09-432c-9f2d-345c84d4b8c6","countryId":"PL","entityName":"Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji)"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"f1cd380acc7a7a5385f2f4447e8ed44d458aa55fba66a353854f731978446f82","citations":[{"url":"https://ofac.treasury.gov/faqs/topic/1521","title":"OFAC, Frequently Asked Questions: Entities Owned by Blocked Persons (50% Rule)","where":"FAQ 398 (ownership, not control), FAQ 399 (50 percent or more in the aggregate; two blocked persons at 25% each block the entity), FAQ 401 (indirect ownership: an entity 50% owned by a blocked entity is blocked and its holdings count in full)"}],"ruleTable":{"fingerprint":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","signedOffOn":"2026-09-17","textsReadOn":"2026-09-13"},"statement":"No party listed under this regime was found on the part of the chain that could be followed. The chain breaks at 1 point, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-18T11:33:36.639Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji)","number":"0000417343","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"wykluczenie z postępowania o udzielenie zamówienia publicznego lub konkursu","entityId":"95d2a4ae-8f09-432c-9f2d-345c84d4b8c6","entityName":"Kaspersky Store Sp. z o.o. (obecnie: ESD STORE Sp. z o.o. w likwidacji)","sourceName":"Poland MSWiA sanctions list","designatedAt":"2022-04-26T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}