{"id":"728aedee-5027-480d-971b-bf5ac916e217","test":"Canadian deemed ownership","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":true,"observedAt":"2026-09-18T11:31:28.758Z","confirmedAt":"2026-10-26T11:31:35.623Z","supersededAt":null,"company":{"id":"3c89b20f-2339-4087-840f-6792d2974c17","name":"MTZ BELARUS TRAKTOR sp. z o.o."},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"Canadian deemed ownership","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":5,"detail":"The holders the KRS lists hold 95% of the capital. The other 5% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"holderName":null},{"share":95,"detail":"BELARUS TRAKTOR KFT. is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"holderName":"BELARUS TRAKTOR KFT."}],"total":2,"byReason":{"unpublished_holders":1,"holder_without_number":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-17T10:47:29.329Z","source":"Canada Consolidated Autonomous Sanctions List","publishedAt":null,"publishedAtBasis":null}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:31:28.759Z","earliest":"2026-09-18T11:31:28.759Z"},"publishedAtBasis":null}]},"caveats":["The company is not listed itself. The Act deems what a company controlled by a listed person owns to be owned by that person, so dealing in the company's property is dealing in the listed person's.","The Act speaks of a person holding 50% or more. Neither the Act nor the guidance of Global Affairs Canada says whether the holdings of different listed persons are added together, so a result reached only by adding them goes to a reviewer.","Global Affairs Canada's guidance, which it says is general information and not legal advice, reads control widely: considerable influence over a company's strategic decisions is enough, and in one of its scenarios so is a listed person on the board of a company's owner.","The Act counts holdings held directly or indirectly, and deems what a controlled company owns, its own holdings included, to be the listed person's in full.","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: MTZ BELARUS TRAKTOR sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000516323","entityId":"3c89b20f-2339-4087-840f-6792d2974c17","countryId":"PL","entityName":"MTZ BELARUS TRAKTOR sp. z o.o."},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"469dd3c89799a01534306f5699c2d1905be2191cb42aa847547f34e8051d3692","citations":[{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/FullText.html","title":"Special Economic Measures Act, S.C. 1992, c. 17, section 2.1 (added by S.C. 2023, c. 26, s. 253)","where":"Subsection 2.1(1): property owned, or held or controlled directly or indirectly, by an entity a person controls is deemed to be owned by that person. Subsection 2.1(2): the person controls the entity if (a) it holds, directly or indirectly, 50% or more of the shares or ownership interests or of the voting rights, (b) it can change the composition or powers of the board, or (c) it can direct the entity's activities by any means"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/J-2.3/FullText.html","title":"Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), S.C. 2017, c. 21, section 2.01","where":"The same deeming provision and criteria, for a foreign national listed under that Act"},{"url":"https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/faq.aspx?lang=eng","title":"Global Affairs Canada, Canadian sanctions: Frequently asked questions (modified 2026-08-14), and Canadian sanctions: Essential information (modified 2026-07-17)","where":"\"Can I deal with the subsidiaries of a designated company?\": the three criteria, a majority-owned subsidiary, and a subsidiary over whose strategic decision-making the parent has considerable influence; Essential information, scenario 3 (a listed person on the board of the buyer's owner)"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/index.html","title":"The Canadian regulations in CANADA_REGULATIONS_APPLIED, as consolidated on Justice Laws","where":"The dealings ban of each, which forbids dealing in property a listed person owns, holds or controls"}],"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 2 points, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-18T11:31:28.758Z","aggregation":"not_settled","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"a. zamrożenie funduszy zgromadzonych na rachunkach bankowych, b. zakaz świadomego i umyślnego udziału w działaniach, których celem lub skutkiem jest ominięcie środków wskazanych w ","entityId":"3c89b20f-2339-4087-840f-6792d2974c17","entityName":"MTZ BELARUS TRAKTOR sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2023-07-22T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}