{"id":"4eb10917-c056-4e1b-9daf-4966e10b1fd4","test":"UK ownership and control","value":"Designated itself, so frozen","current":false,"observedAt":"2026-09-16T14:45:33.374Z","confirmedAt":"2026-09-16T14:45:33.374Z","supersededAt":"2026-09-17T11:35:23.591Z","company":{"id":"ea55d451-34e4-4b5a-9355-4d1b86c2620e","name":"GARANTEX EUROPE OU"},"previous":{"id":"25cf4084-3083-4034-b2ea-b2c6bd5008b8","value":"Designated itself, so frozen","observedAt":"2026-09-14T09:27:49.843Z","supersededAt":"2026-09-16T14:45:33.374Z"},"next":{"id":"99c3e9e0-6a3a-4c90-bf70-4b20af3e01e4","value":"Designated itself, so frozen","observedAt":"2026-09-17T11:35:23.591Z","supersededAt":"2026-09-18T11:35:38.371Z"},"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":"GARANTEX EUROPE OU","number":"14850239","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":"frozen","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":"designated","subject":{"number":"14850239","entityId":"ea55d451-34e4-4b5a-9355-4d1b86c2620e","countryId":"EE","entityName":"GARANTEX EUROPE OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"5616196ae60ded4640c360170d553f5ed8c4ca3328f723e5564a369873b5d6f0","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":"8826482c6e3d3ac72d2b2edf419a0b09ba86883deafffb9cccd0a38fcf649b4c","signedOffOn":"2026-09-15","textsReadOn":"2026-09-13"},"statement":"The company is itself listed under this regime, and frozen as a listed party rather than through its owners.","threshold":"more than 50%","computedAt":"2026-09-16T14:45:33.374Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"GARANTEX EUROPE OU","number":"14850239","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"CYBER4","entityId":"ea55d451-34e4-4b5a-9355-4d1b86c2620e","entityName":"GARANTEX EUROPE OU","sourceName":"OFAC SDN","designatedAt":null},{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"ea55d451-34e4-4b5a-9355-4d1b86c2620e","entityName":"GARANTEX EUROPE OU","sourceName":"OFAC SDN","designatedAt":null},{"kind":"asset_freeze","test":"UK ownership and control","regime":"UK OFSI","status":"rule_verified","program":"Russia","entityId":"ea55d451-34e4-4b5a-9355-4d1b86c2620e","entityName":"GARANTEX EUROPE OU","sourceName":"UK Sanctions List (FCDO)","designatedAt":"2022-05-04T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}