{"id":"4f853903-1b4b-4145-8cf9-df13988db183","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-25T20:31:02.542Z","confirmedAt":"2026-10-24T12:17:41.241Z","supersededAt":null,"company":{"id":"776acdaa-8b67-4793-be63-d9cb0def8151","name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"previous":{"id":"2921039c-eb0a-49a1-8d05-7b2a9887a513","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:32:52.512Z","supersededAt":"2026-09-25T20:31:02.542Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","notes":["Sabiedrība ar ierobežotu atbildību \"RAPIRA\" holds 50% of itself. Own shares carry no owner to follow and are left out of the chain; percentages are not re-based around them.","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":[],"total":0,"byReason":{}},"change":{"was":"No designated company found in the chain; the people in it are compared by name only","from":"2921039c-eb0a-49a1-8d05-7b2a9887a513","lines":["Listed now: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" on Australia DFAT Consolidated List (Australia DFAT, Autonomous (Russia))"],"causes":["list"],"answerChanged":false},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-21T19:17:22.809Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-21T00:00:00.000Z","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":"2026-09-19T10:30:34.868Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-18T20:25:35.000Z","holdingsReadAt":{"latest":"2026-09-19T10:30:00.011Z","earliest":"2026-09-19T10:30:00.011Z"},"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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" (Australia DFAT Consolidated List)."],"outcome":"no_designated_holder_found","subject":{"number":"40103322761","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"holdings":{"total":2,"heldByCompanies":1,"notPublishedAsCompanies":1},"identity":"13cf55de9d9a2f93ede210c412d4a8792e8156a94df5a32e88bf1c4021292e24","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 company listed under this regime holds any share of the company, anywhere in the chain the registers state. Natural persons hold one holding in the chain, including 50% of the company directly. The registers publish no identifier that confirms who they are, so they were compared with designated persons by name only, and a name written differently in a register and on a list is not found.","threshold":"more than 50%","computedAt":"2026-09-25T20:31:02.542Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","number":"40103322761","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Australia DFAT","status":"not_verified","program":"Autonomous (Russia)","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","sourceName":"Australia DFAT Consolidated List","designatedAt":null,"sanctionType":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":50}}}