{"id":"1dba6e59-1da7-42af-b514-88cf440752c5","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":false,"observedAt":"2026-09-16T14:43:29.921Z","confirmedAt":"2026-09-16T14:43:29.921Z","supersededAt":"2026-09-17T11:33:43.290Z","company":{"id":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","name":"DONCOALTRADE SP Z O O"},"previous":{"id":"5ab3ff8a-c7fe-43fc-a5ac-e0c1b873da2e","value":"Designated itself, so blocked","observedAt":"2026-09-14T09:27:07.015Z","supersededAt":"2026-09-16T14:43:29.921Z"},"next":{"id":"f5658991-e9c3-42c9-9074-ebbd92cfbcb5","value":"Designated itself, so blocked","observedAt":"2026-09-17T11:33:43.290Z","supersededAt":"2026-09-18T11:33:54.933Z"},"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":"The KRS struck this company off the register on 26.11.2024, so it publishes no current holders for it.","reason":"not_found_in_register","company":{"name":"DONCOALTRADE SP Z O O","number":"0000421465","countryId":"PL"},"holderName":null}],"total":1,"byReason":{"not_found_in_register":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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":null,"publishedAtBasis":null}]},"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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: DONCOALTRADE SP Z O O (US Consolidated Screening List)."],"outcome":"designated","subject":{"number":"0000421465","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","countryId":"PL","entityName":"DONCOALTRADE SP Z O O"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"fa7be50f0504552e7df55a2e0bdbba4dd82ae1816281f6f789b33847acca39f5","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":"8826482c6e3d3ac72d2b2edf419a0b09ba86883deafffb9cccd0a38fcf649b4c","signedOffOn":"2026-09-15","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":"2026-09-16T14:43:29.921Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"DONCOALTRADE SP Z O O","number":"0000421465","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"UKRAINE-EO13660","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","entityName":"DONCOALTRADE SP Z O O","sourceName":"OFAC SDN","designatedAt":null},{"kind":"export_control","test":null,"regime":"US CSL (EL)","status":"not_verified","program":"Entity List (EL) - Bureau of Industry and Security","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","entityName":"DONCOALTRADE SP Z O O","sourceName":"US Consolidated Screening List","designatedAt":"2018-02-16T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}