{"id":"55cc1b23-5c57-425c-8410-c220529e7555","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-14T09:25:29.883Z","confirmedAt":"2026-09-16T13:30:00.084Z","supersededAt":"2026-09-16T14:38:30.548Z","company":{"id":"000a6144-1bbd-470d-b5af-a8503bf3a38e","name":"SIA \"SKS Realty\""},"previous":null,"next":{"id":"a1dd7c6f-e26f-4c01-943b-49f76e9c8e31","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-16T14:38:30.548Z","supersededAt":"2026-09-17T11:30:00.058Z"},"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":[],"total":0,"byReason":{}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-13T15:07:31.157Z","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":"2026-09-14T08:59:58.987Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-13T20:25:36.000Z","holdingsReadAt":{"latest":"2026-09-14T08:59:33.866Z","earliest":"2026-09-14T08:59:33.866Z"},"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":"40103681325","entityId":"000a6144-1bbd-470d-b5af-a8503bf3a38e","countryId":"LV","entityName":"SIA \"SKS Realty\""},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"424f4aab338267b267fa7037259176ca88efad1b0487bec74a90f8e0beb24290","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":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","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 2 holdings in the chain, including 100% 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":"2026-09-14T09:25:29.883Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","listedParties":[],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"No designated company appears anywhere in the chain the registers state. Natural persons in the chain were compared with designated persons by name only.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":0,"directShareOfSubject":100}}}