{"id":"10c3f4e3-f5f0-4cd8-b19b-c2e0989017e9","test":"Swiss ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-17T11:33:45.514Z","confirmedAt":"2026-09-17T11:33:45.514Z","supersededAt":"2026-09-18T11:33:57.071Z","company":{"id":"a3f16b68-4331-40c0-baf9-652da45140d2","name":"Produktaiest OÜ"},"previous":null,"next":{"id":"93b62f7a-4339-45da-8e7a-79ae8bcd36b2","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-18T11:33:57.071Z","supersededAt":null},"derivation":{"kind":"ownership_verdict","path":[],"test":"Swiss 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":null,"detail":"No register read here states who owns companies registered in LT, so the chain stops at this company.","reason":"no_ownership_register","company":{"name":"UAB \"Litproduktai\"","number":"305088459","countryId":"LT"},"holderName":null}],"total":1,"byReason":{"no_ownership_register":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-16T22:01:40.056Z","source":"Switzerland SECO Sanctions List","publishedAt":"2026-09-04T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":{"latest":"2026-09-14T08:58:29.708Z","earliest":"2026-09-14T08:58:29.708Z"},"publishedAtBasis":"server_last_modified"}]},"caveats":["What owning and controlling mean is set out in SECO's guidance on the sanctions ordinances, which SECO says is not legally binding.","SECO adds the holdings of several sanctioned parties together \"in principle\" (grundsätzlich).","Control raises a presumption that the company may rebut case by case.","SECO counts holdings held directly or indirectly, and publishes no worked example with percentages. A company owned at the threshold is treated as holding its own shares for the listed party, as under the EU test.","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.","2 parties in this chain are listed under a regime whose ownership rule has not been verified here, and were not counted: Produktaiest OÜ (Latvia FID frozen assets register); UAB \"Litproduktai\" (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"16187331","entityId":"a3f16b68-4331-40c0-baf9-652da45140d2","countryId":"EE","entityName":"Produktaiest OÜ"},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"3d7747f691666e125b3c60ef2f3765a945e17414994033805ecf9be6cda4bb22","citations":[{"url":"https://www.seco.admin.ch/dam/de/sd-web/Vjbtwu26yOgQ/Auslegungshilfe%20f%C3%BCr%20Sanktionsmassnahmen.pdf","title":"SECO, Auslegungshilfe Sanktionsmassnahmen (Stand 30. Juni 2026)","where":"Chapter 1, which applies to every sanctions ordinance that freezes funds: 1.10 (owning: 50% or more of the ownership interests, directly or indirectly; the interests of several sanctioned parties added together in principle) and 1.11 (control: any one of criteria a to h, unless the contrary is shown in the case)"},{"url":"https://www.fedlex.admin.ch/","title":"The Swiss sanctions ordinances in SWISS_ORDINANCES_READ, as consolidated on fedlex","where":"The freeze article of each, which freezes the funds and economic resources owned or controlled by the listed parties, by parties acting on their behalf, and by companies and organisations those parties own or control"}],"ruleTable":{"fingerprint":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","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":"2026-09-17T11:33:45.514Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Produktaiest OÜ","number":"16187331","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi","entityId":"a3f16b68-4331-40c0-baf9-652da45140d2","entityName":"Produktaiest OÜ","sourceName":"Latvia FID frozen assets register","designatedAt":null}]},{"hops":1,"company":{"name":"UAB \"Litproduktai\"","number":"305088459","countryId":"LT"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi","entityId":"112c3d2e-b96c-4c49-8367-8b10bc817e19","entityName":"Litproduktai UAB","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}