{"id":"05302c62-80c2-430e-88f2-d080adaeed17","test":"UK ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:34:21.814Z","confirmedAt":"2026-10-25T11:34:13.208Z","supersededAt":null,"company":{"id":"b6a372f0-c275-45bd-abbc-122eea5fabe2","name":"SIA \"Severstal Distribution\""},"previous":{"id":"bb07d9bd-e547-4d4e-a8c4-3c0b3c82bc38","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:34:09.719Z","supersededAt":"2026-09-18T11:34:21.814Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","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":100,"detail":"MARCEGAGLIA CARBON STEEL S.P.A. is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"Severstal Distribution\"","number":"40003001968","countryId":"LV"},"holderName":"MARCEGAGLIA CARBON STEEL S.P.A."}],"total":1,"byReason":{"holder_without_number":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-14T19:10:36.796Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-11T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-09-13T14:36:27.699Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"registers":[{"readAt":"2026-09-14T21:54:42.782Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-14T20:25:33.000Z","holdingsReadAt":{"latest":"2026-09-14T21:53:47.938Z","earliest":"2026-09-14T21:53:47.938Z"},"publishedAtBasis":"server_last_modified"}]},"caveats":["Holdings of different designated persons are not added together unless the shares are subject to a joint arrangement between them or one controls the rights of another.","Control without the threshold stake is part of this test and cannot be read from a shareholder register, so an outcome short of the threshold does not mean the company is not controlled."],"outcome":"no_designated_holder_found","subject":{"number":"40003001968","entityId":"b6a372f0-c275-45bd-abbc-122eea5fabe2","countryId":"LV","entityName":"SIA \"Severstal Distribution\""},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"6829aff7e21eb2911c73947cc63902d2c5870130b04947df06b042dde618f64f","citations":[{"url":"https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance","title":"OFSI, UK financial sanctions general guidance (updated 12 May 2026)","where":"Section 4.1 (more than 50% of shares or voting rights, or control), 4.1.3 (a designated person owns what it owns jointly with another) and 4.1.4 (holdings of different designated persons not simply aggregated)"},{"url":"https://www.legislation.gov.uk/uksi/2019/855/schedule/1","title":"The Russia (Sanctions) (EU Exit) Regulations 2019, Schedule 1","where":"Paragraph 2 (each joint holder of a share is treated as holding that share), paragraph 3 (joint arrangements), paragraph 4 (more than 50% of share capital), paragraph 9 (indirect holding through a chain of majority stakes). Each UK regulation this test is applied under was read, and carries the same definition and rules."}],"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":"more than 50%","computedAt":"2026-09-18T11:34:21.814Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"No designated party was reached on the part of the chain that could be followed, which breaks at 1 point.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}