{"id":"3cad6806-41cf-4ece-99a7-60d3cabadac1","test":"UK ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:33:04.189Z","confirmedAt":"2026-10-26T11:33:20.281Z","supersededAt":null,"company":{"id":"8041f643-7c86-4e67-9610-b71f0975a92f","name":"ELFARO OU"},"previous":{"id":"809986e4-7ecb-4e50-be3d-9c94bbdd8302","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:32:53.857Z","supersededAt":"2026-09-18T11:33:04.189Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","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":"ELFARO OU","number":"14329778","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-14T19:10:36.796Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-11T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-09-13T14:36:27.699Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"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":["Holdings of different designated persons are not added together unless the shares are subject to a joint arrangement between them or one controls the rights of another.","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."],"outcome":"no_designated_holder_found","subject":{"number":"14329778","entityId":"8041f643-7c86-4e67-9610-b71f0975a92f","countryId":"EE","entityName":"ELFARO OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"1075329191be58d50ed18534f200b1fdbc8391c1f5367a819dc0d3c06d787dad","citations":[{"url":"https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance","title":"OFSI, UK financial sanctions general guidance (updated 12 May 2026)","where":"Section 4.1 (more than 50% of shares or voting rights, or control), 4.1.3 (a designated person owns what it owns jointly with another) and 4.1.4 (holdings of different designated persons not simply aggregated)"},{"url":"https://www.legislation.gov.uk/uksi/2019/855/schedule/1","title":"The Russia (Sanctions) (EU Exit) Regulations 2019, Schedule 1","where":"Paragraph 2 (each joint holder of a share is treated as holding that share), paragraph 3 (joint arrangements), paragraph 4 (more than 50% of share capital), paragraph 9 (indirect holding through a chain of majority stakes). Each UK regulation this test is applied under was read, and carries the same definition and rules."}],"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 1 point, and past a break nothing is known.","threshold":"more than 50%","computedAt":"2026-09-18T11:33:04.189Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"ELFARO OU","number":"14329778","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"8041f643-7c86-4e67-9610-b71f0975a92f","entityName":"ELFARO OU","sourceName":"OFAC SDN","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}}}