{"id":"154f60cc-6734-4014-8284-061a53a5371e","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":true,"observedAt":"2026-09-18T11:32:30.767Z","confirmedAt":"2026-10-27T11:32:25.709Z","supersededAt":null,"company":{"id":"681b63cf-c704-4cd1-b5c3-3f29549924e7","name":"FREE SKY SOLUTIONS OU"},"previous":{"id":"69cf9072-e87d-448b-a52b-19a9d5272f63","value":"Designated itself, so blocked","observedAt":"2026-09-17T11:32:20.852Z","supersededAt":"2026-09-18T11:32:30.767Z"},"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":"Estonia e-Business Register (shareholders) holds no shareholder rows for this company. Neither Baltic register publishes the shareholders of a joint-stock company, so this is not evidence that it has none.","reason":"no_holders_published","company":{"name":"FREE SKY SOLUTIONS OU","number":"EE102381957","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":"blocked","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":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":null,"publishedAtBasis":"server_last_modified"}]},"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."],"outcome":"designated","subject":{"number":"EE102381957","entityId":"681b63cf-c704-4cd1-b5c3-3f29549924e7","countryId":"EE","entityName":"FREE SKY SOLUTIONS OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"32b9ca26682f4cf1dcc4b3bd988511e50cb9f60a067207f187ca59c6cbe9a0e0","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":"The company is itself listed under this regime, and blocked as a listed party rather than through its owners.","threshold":"50% or more","computedAt":"2026-09-18T11:32:30.767Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"FREE SKY SOLUTIONS OU","number":"EE102381957","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"681b63cf-c704-4cd1-b5c3-3f29549924e7","entityName":"FREE SKY SOLUTIONS OU","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}