{"id":"61228b81-a499-4e9b-a51b-ba8a16bbceb9","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 3 points","current":true,"observedAt":"2026-09-18T11:31:04.685Z","confirmedAt":"2026-10-24T12:15:59.143Z","supersededAt":null,"company":{"id":"2b1cdc0b-0fb4-47bb-988c-19d362827872","name":"TORGSERVIS PL sp. z o.o."},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["2 natural-person holdings are published with a masked name and were compared with nobody.","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":6,"detail":"The holders the KRS lists hold 94% of the capital. The other 6% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"TORGSERVIS PL sp. z o.o.","number":"0000680860","countryId":"PL"},"holderName":null},{"share":15,"detail":null,"reason":"holder_name_masked","company":{"name":"TORGSERVIS PL sp. z o.o.","number":"0000680860","countryId":"PL"},"holderName":null},{"share":79,"detail":null,"reason":"holder_name_masked","company":{"name":"TORGSERVIS PL sp. z o.o.","number":"0000680860","countryId":"PL"},"holderName":null}],"total":3,"byReason":{"holder_name_masked":2,"unpublished_holders":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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:31:04.690Z","earliest":"2026-09-18T11:31:04.690Z"},"publishedAtBasis":null}]},"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: TORGSERVIS PL sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000680860","entityId":"2b1cdc0b-0fb4-47bb-988c-19d362827872","countryId":"PL","entityName":"TORGSERVIS PL sp. z o.o."},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"bcf3f40005a1bc2416c3b30e9b4ad22811376184015b985e9d2ca36092c10b1e","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 3 points, and past a break nothing is known. Natural persons hold 2 holdings in the chain, including 94% of the company directly. The register publishes their names masked, so none of them was compared with any designated person.","threshold":"50% or more","computedAt":"2026-09-18T11:31:04.685Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"TORGSERVIS PL sp. z o.o.","number":"0000680860","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"a. zamrożenie wszystkich środków finansowych i zasobów gospodarczych, b. zakaz udostępniania podmiotowi wpisanemu na listę lub na jego rzecz – bezpośrednio lub pośrednio – jakichko","entityId":"2b1cdc0b-0fb4-47bb-988c-19d362827872","entityName":"TORGSERVIS PL sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2025-04-25T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":94}}}