{"id":"1371283a-3057-4e75-bd3e-909bfdbd588d","test":"EU owning or controlling","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":true,"observedAt":"2026-09-18T11:30:48.505Z","confirmedAt":"2026-10-25T11:30:47.761Z","supersededAt":null,"company":{"id":"1eae17d8-ec34-44c4-8d83-f44bd4abb308","name":"REIVEN TECHNOLOGIES POLSKA sp. z o.o."},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"EU owning or controlling","notes":["1 natural-person holding is published with a masked name and was compared with nobody.","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":9,"detail":"The holders the KRS lists hold 91% of the capital. The other 9% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"REIVEN TECHNOLOGIES POLSKA sp. z o.o.","number":"0000938309","countryId":"PL"},"holderName":null},{"share":91,"detail":null,"reason":"holder_name_masked","company":{"name":"REIVEN TECHNOLOGIES POLSKA sp. z o.o.","number":"0000938309","countryId":"PL"},"holderName":null}],"total":2,"byReason":{"holder_name_masked":1,"unpublished_holders":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-13T14:34:50.281Z","source":"EU Consolidated Sanctions List","publishedAt":"2026-08-05T14:47:04.449Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:30:48.508Z","earliest":"2026-09-18T11:30:48.508Z"},"publishedAtBasis":null}]},"caveats":["Ownership raises a presumption that the listed person controls the entity and its assets. The entity may rebut it case by case.","Regulations 269/2014 and 2580/2001 define owning and controlling themselves. For the other EU regimes read here, the same test is the one the Council sets out in its Best Practices, which are not legally binding.","The Commission says control over an entity also reaches that entity's own subsidiaries, but publishes no worked example with percentages. A company owned at the threshold is treated as holding its own shares for the listed person on that basis.","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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: REIVEN TECHNOLOGIES POLSKA sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000938309","entityId":"1eae17d8-ec34-44c4-8d83-f44bd4abb308","countryId":"PL","entityName":"REIVEN TECHNOLOGIES POLSKA sp. z o.o."},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"b7d97ce83ff199764a057ae24343c923b28e73b9da15fb25066a533b8cdfedac","citations":[{"url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2037","title":"Council Regulation (EU) No 269/2014, Article 1, as amended by Council Regulation (EU) 2025/2037 of 23 October 2025","where":"Article 1, points (i) \"owning\": 50% or more of the proprietary rights, and (j) \"controlling\""},{"url":"https://data.consilium.europa.eu/doc/document/ST-11623-2024-INIT/en/pdf","title":"Council of the European Union, EU Best Practices for the effective implementation of restrictive measures, document 11623/24 of 3 July 2024","where":"Paragraph 62 (the freeze reaches assets of entities owned or controlled by a listed person), 63 (owned: 50% or more of the proprietary rights, holdings of listed persons aggregated), 64 to 66 (control criteria, rebuttable) and 68 (funds made available to an owned or controlled entity are made available indirectly to the listed person). Applied to each EU regime in EU_REGULATIONS_READ."},{"url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02001R2580-20260227","title":"Council Regulation (EC) No 2580/2001, Article 1","where":"Article 1, points (k) \"owning\": 50% or more of the proprietary rights or a majority interest, and (l) \"controlling\""},{"url":"https://finance.ec.europa.eu/system/files/2023-07/faqs-sanctions-russia-assets-freezes_en.pdf","title":"European Commission, Frequently asked questions: asset freeze under Council Regulation 269/2014 (as of 6 May 2026)","where":"Question 1 (presumption that control extends to the assets of an owned or controlled entity, rebuttable), Question 8 (aggregated ownership of several listed persons) and Question 9 (control over one entity reaches its own subsidiaries)"}],"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 2 points, and past a break nothing is known. Natural persons hold one holding in the chain, including 91% of the company directly. The register publishes that person's name masked, so it was compared with no designated person.","threshold":"50% or more","computedAt":"2026-09-18T11:30:48.505Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"REIVEN TECHNOLOGIES POLSKA sp. z o.o.","number":"0000938309","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"a. zamrożenie wszystkich środków finansowych i zasobów gospodarczych, b. zakaz udostępniania podmiotowi wpisanemu na listę lub na jego rzecz – bezpośrednio lub pośrednio – jakichko","entityId":"1eae17d8-ec34-44c4-8d83-f44bd4abb308","entityName":"REIVEN TECHNOLOGIES POLSKA sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2024-06-12T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":1,"directShareOfSubject":91}}}