{"id":"2bf9edc9-397d-441d-9f94-6d736fbbc077","test":"Canadian deemed ownership","value":"No designated holder found where the chain could be followed; it breaks at 3 points","current":true,"observedAt":"2026-09-18T11:31:44.165Z","confirmedAt":"2026-10-26T11:31:52.331Z","supersededAt":null,"company":{"id":"47dc6f1c-6cca-4ec3-b54e-6f2c078a15b4","name":"ALLIANCE CAPITAL KS Sp. z o.o."},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"Canadian deemed ownership","notes":["2 natural-person holdings are published with a masked name and were 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":65,"detail":"The holders the KRS lists hold 35% of the capital. The other 65% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"ALLIANCE CAPITAL KS Sp. z o.o.","number":"0000856567","countryId":"PL"},"holderName":null},{"share":10,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS Sp. z o.o.","number":"0000856567","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS Sp. z o.o.","number":"0000856567","countryId":"PL"},"holderName":null}],"total":3,"byReason":{"holder_name_masked":2,"unpublished_holders":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-17T10:47:29.329Z","source":"Canada Consolidated Autonomous Sanctions List","publishedAt":null,"publishedAtBasis":null}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:31:44.167Z","earliest":"2026-09-18T11:31:44.167Z"},"publishedAtBasis":null}]},"caveats":["The company is not listed itself. The Act deems what a company controlled by a listed person owns to be owned by that person, so dealing in the company's property is dealing in the listed person's.","The Act speaks of a person holding 50% or more. Neither the Act nor the guidance of Global Affairs Canada says whether the holdings of different listed persons are added together, so a result reached only by adding them goes to a reviewer.","Global Affairs Canada's guidance, which it says is general information and not legal advice, reads control widely: considerable influence over a company's strategic decisions is enough, and in one of its scenarios so is a listed person on the board of a company's owner.","The Act counts holdings held directly or indirectly, and deems what a controlled company owns, its own holdings included, to be the listed person's in full.","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: ALLIANCE CAPITAL KS Sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000856567","entityId":"47dc6f1c-6cca-4ec3-b54e-6f2c078a15b4","countryId":"PL","entityName":"ALLIANCE CAPITAL KS Sp. z o.o."},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"440e9abd595458657f6b23393b0a7573bb29c5bb3ce4570f47170fbdc36ebe29","citations":[{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/FullText.html","title":"Special Economic Measures Act, S.C. 1992, c. 17, section 2.1 (added by S.C. 2023, c. 26, s. 253)","where":"Subsection 2.1(1): property owned, or held or controlled directly or indirectly, by an entity a person controls is deemed to be owned by that person. Subsection 2.1(2): the person controls the entity if (a) it holds, directly or indirectly, 50% or more of the shares or ownership interests or of the voting rights, (b) it can change the composition or powers of the board, or (c) it can direct the entity's activities by any means"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/J-2.3/FullText.html","title":"Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), S.C. 2017, c. 21, section 2.01","where":"The same deeming provision and criteria, for a foreign national listed under that Act"},{"url":"https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/faq.aspx?lang=eng","title":"Global Affairs Canada, Canadian sanctions: Frequently asked questions (modified 2026-08-14), and Canadian sanctions: Essential information (modified 2026-07-17)","where":"\"Can I deal with the subsidiaries of a designated company?\": the three criteria, a majority-owned subsidiary, and a subsidiary over whose strategic decision-making the parent has considerable influence; Essential information, scenario 3 (a listed person on the board of the buyer's owner)"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/index.html","title":"The Canadian regulations in CANADA_REGULATIONS_APPLIED, as consolidated on Justice Laws","where":"The dealings ban of each, which forbids dealing in property a listed person owns, holds or controls"}],"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 3 points, and past a break nothing is known. Natural persons hold 2 holdings in the chain, including 35% of the company directly. The register publishes their names masked, so none of them was compared with any designated person.","threshold":"50% or more","computedAt":"2026-09-18T11:31:44.165Z","aggregation":"not_settled","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"ALLIANCE CAPITAL KS Sp. z o.o.","number":"0000856567","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":"47dc6f1c-6cca-4ec3-b54e-6f2c078a15b4","entityName":"ALLIANCE CAPITAL KS Sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2026-04-28T00:00:00.000Z"},{"kind":"asset_freeze","test":"UK ownership and control","regime":"UK OFSI","status":"rule_verified","program":"Russia","entityId":"fe552d6f-3f04-4e38-aad5-9463c4333454","entityName":"ALLIANCE CAPITAL KS SP Z O O","sourceName":"UK Sanctions List (FCDO)","designatedAt":"2026-02-24T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":35}}}