{"id":"704827c7-9ae6-44f7-a3db-633789bbc61d","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":"2026-09-17T11:32:28.042Z","confirmedAt":"2026-09-17T11:32:28.042Z","supersededAt":"2026-09-18T11:32:37.427Z","company":{"id":"6d2a18d7-a390-4fcd-8e85-7c20ba97ab83","name":"Sabiedrība ar ierobežotu atbildību \"KATALINA\""},"previous":{"id":"0e738f53-13b4-46f1-89d0-673cabd064ff","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-16T14:41:53.812Z","supersededAt":"2026-09-17T11:32:28.042Z"},"next":{"id":"f675b9cb-62e9-4e7e-8e91-985b684fb417","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:32:37.427Z","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":"40203483053","entityId":"6d2a18d7-a390-4fcd-8e85-7c20ba97ab83","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"KATALINA\""},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"47eee0407e49c77d97f02cdd30ae7a65277ae3bc40f91f9bb5456fb9ff23f16a","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 one holding 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":"2026-09-17T11:32:28.042Z","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":1,"masked":0,"directShareOfSubject":100}}}