{"id":"1bb49b2b-b9b5-4f0d-989c-bc71901f75f4","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-14T09:27:07.932Z","confirmedAt":"2026-09-16T13:31:19.275Z","supersededAt":"2026-09-16T14:43:32.912Z","company":{"id":"a3f16b68-4331-40c0-baf9-652da45140d2","name":"Produktaiest OÜ"},"previous":null,"next":{"id":"606bc3fb-38b2-49a2-a9f0-1be784b65e5d","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:43:32.912Z","supersededAt":"2026-09-17T11:33:45.514Z"},"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":"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":"2026-09-13T14:47:39.470Z","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":{"latest":"2026-09-14T08:58:29.708Z","earliest":"2026-09-14T08:58:29.708Z"},"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.","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":"b8339762e812b8240fd5198fee99622b67bbc065f383618b79ddd5a910d72f26","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":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","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":"2026-09-14T09:27:07.932Z","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}}}