{"id":"6d2b50d2-c200-40ca-8fae-dd8687c7eac4","test":"OFAC 50 percent rule","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-17T11:30:00.058Z","confirmedAt":"2026-09-17T11:30:00.058Z","supersededAt":"2026-09-18T11:30:00.065Z","company":{"id":"000a6144-1bbd-470d-b5af-a8503bf3a38e","name":"SIA \"SKS Realty\""},"previous":{"id":"0c8edd97-1a64-4707-b562-ede005505c7c","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"},"next":{"id":"69c1075a-6974-4048-a33a-5e9a154a12ae","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:30:00.065Z","supersededAt":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":[],"total":0,"byReason":{}},"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."],"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":"25c18b4e8113bb83cf08bef6fbd5c11f740860db5d78b05725b9047f3ef3c3f8","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":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","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 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":"50% or more","computedAt":"2026-09-17T11:30:00.058Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","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}}}