{"id":"5a490c2c-b130-43b4-8187-07000b10f5bd","test":"Swiss ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:34:24.104Z","confirmedAt":"2026-10-24T12:19:08.188Z","supersededAt":null,"company":{"id":"b84baa2f-f57b-4605-90f6-142eb27dfd99","name":"Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā"},"previous":{"id":"4c01f54d-9834-4ef5-a38d-14dcacd303a5","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:34:11.918Z","supersededAt":"2026-09-18T11:34:24.104Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"Swiss 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":"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":"Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā","number":"40203286467","countryId":"LV"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-16T22:01:40.056Z","source":"Switzerland SECO Sanctions List","publishedAt":"2026-09-04T00:00:00.000Z","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":null,"publishedAtBasis":"server_last_modified"}]},"caveats":["What owning and controlling mean is set out in SECO's guidance on the sanctions ordinances, which SECO says is not legally binding.","SECO adds the holdings of several sanctioned parties together \"in principle\" (grundsätzlich).","Control raises a presumption that the company may rebut case by case.","SECO counts holdings held directly or indirectly, and publishes no worked example with percentages. A company owned at the threshold is treated as holding its own shares for the listed party, as under the EU test.","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: Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"40203286467","entityId":"b84baa2f-f57b-4605-90f6-142eb27dfd99","countryId":"LV","entityName":"Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"ff0b86589ded101dcd055964035fd50c732e1260c09f739257ac5bbcac46f241","citations":[{"url":"https://www.seco.admin.ch/dam/de/sd-web/Vjbtwu26yOgQ/Auslegungshilfe%20f%C3%BCr%20Sanktionsmassnahmen.pdf","title":"SECO, Auslegungshilfe Sanktionsmassnahmen (Stand 30. Juni 2026)","where":"Chapter 1, which applies to every sanctions ordinance that freezes funds: 1.10 (owning: 50% or more of the ownership interests, directly or indirectly; the interests of several sanctioned parties added together in principle) and 1.11 (control: any one of criteria a to h, unless the contrary is shown in the case)"},{"url":"https://www.fedlex.admin.ch/","title":"The Swiss sanctions ordinances in SWISS_ORDINANCES_READ, as consolidated on fedlex","where":"The freeze article of each, which freezes the funds and economic resources owned or controlled by the listed parties, by parties acting on their behalf, and by companies and organisations those parties own or control"}],"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":"50% or more","computedAt":"2026-09-18T11:34:24.104Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā","number":"40203286467","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi, kapitāldaļas, nekustamais īpašums","entityId":"b84baa2f-f57b-4605-90f6-142eb27dfd99","entityName":"Ārvalsts komersanta UAB \"Valiente\" filiāle Latvijā","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}}}