{"id":"1c3e2963-7267-43bd-9007-1cc6e2acd0a2","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":false,"observedAt":"2026-09-17T11:33:49.879Z","confirmedAt":"2026-09-17T11:33:49.879Z","supersededAt":"2026-09-18T11:34:01.528Z","company":{"id":"a701ffcf-ac96-48cb-ac26-dda7eef89723","name":"BITFINGROUP OU"},"previous":{"id":"b880b165-a95d-4390-bc12-37f4c0a33874","value":"Designated itself, so blocked","observedAt":"2026-09-16T14:43:38.775Z","supersededAt":"2026-09-17T11:33:49.879Z"},"next":{"id":"29bf13c2-22f2-4836-b5f7-ccb0326f2d2d","value":"Designated itself, so blocked","observedAt":"2026-09-18T11:34:01.528Z","supersededAt":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":"BITFINGROUP OU","number":"16323700","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":"16323700","entityId":"a701ffcf-ac96-48cb-ac26-dda7eef89723","countryId":"EE","entityName":"BITFINGROUP OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"f1f4362e0318c4cb55a6ab6b82324b35a82432d26ccb59cd233b10a327c9f953","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":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","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":"2026-09-17T11:33:49.879Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"BITFINGROUP OU","number":"16323700","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"a701ffcf-ac96-48cb-ac26-dda7eef89723","entityName":"BITFINGROUP 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}}}