{"id":"516a8bda-6040-4fcf-87bd-b528916e77d2","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":true,"observedAt":"2026-09-18T11:33:47.960Z","confirmedAt":"2026-10-27T11:33:40.678Z","supersededAt":null,"company":{"id":"9d349790-f488-425f-8618-53f8a2d0a67f","name":"SIA \"VENTAMONJAKS\""},"previous":{"id":"aac98979-d676-47a6-adc3-1e4bb902249a","value":"No designated holder found where the chain could be followed; it breaks at 2 points","observedAt":"2026-09-17T11:33:36.522Z","supersededAt":"2026-09-18T11:33:47.960Z"},"next":null,"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":54.99999955163228,"detail":"TAMMULOGIS LIMITED is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"VENTAMONJAKS\"","number":"41203050838","countryId":"LV"},"holderName":"TAMMULOGIS LIMITED"},{"share":null,"detail":"Latvia Enterprise Register (members) 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":"AS \"HALCYON CAPITAL\"","number":"50103755611","countryId":"LV"},"holderName":null}],"total":2,"byReason":{"no_holders_published":1,"holder_without_number":1}},"effect":null,"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":"2026-09-14T21:54:42.782Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-14T20:25:33.000Z","holdingsReadAt":{"latest":"2026-09-14T21:53:47.938Z","earliest":"2026-09-14T21:53:47.938Z"},"publishedAtBasis":"server_last_modified"}]},"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: SIA \"VENTAMONJAKS\" (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"41203050838","entityId":"9d349790-f488-425f-8618-53f8a2d0a67f","countryId":"LV","entityName":"SIA \"VENTAMONJAKS\""},"holdings":{"total":2,"heldByCompanies":2,"notPublishedAsCompanies":0},"identity":"becaa5ad7544941e95f86d577f495f64605e4c535be6e43ad9040de8fe8cba6d","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":"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 2 points, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-18T11:33:47.960Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA \"VENTAMONJAKS\"","number":"41203050838","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi; kapitāldaļas; inženierbūve; nekustamie īpašumi","entityId":"9d349790-f488-425f-8618-53f8a2d0a67f","entityName":"SIA \"VENTAMONJAKS\"","sourceName":"Latvia FID frozen assets register","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}}}