{"id":"747b9af0-d64a-4616-8886-88d54c215460","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":true,"observedAt":"2026-10-19T11:33:25.098Z","confirmedAt":"2026-10-26T11:33:59.355Z","supersededAt":null,"company":{"id":"91517e70-b8e1-4349-aa06-8b54cf6237a1","name":"ELMAK"},"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":51.01701951017019,"detail":null,"reason":"holder_name_masked","company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"holderName":null},{"share":48.98298048982981,"detail":null,"reason":"holder_name_masked","company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"holderName":null}],"total":2,"byReason":{"holder_name_masked":2}},"effect":"blocked","inputs":{"lists":[{"readAt":"2026-10-19T04:11:19.630Z","source":"OFAC SDN","publishedAt":"2026-10-15T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-10-19T11:33:25.100Z","earliest":"2026-10-19T11:33:25.100Z"},"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."],"outcome":"designated","subject":{"number":"0000113334","entityId":"91517e70-b8e1-4349-aa06-8b54cf6237a1","countryId":"PL","entityName":"ELMAK"},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"5265a1ffd12fedc31a11cfe89c24f7e166063e5a8d22b13d5d73e4c833443cf1","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":"The company is itself listed under this regime, and blocked as a listed party rather than through its owners.","threshold":"50% or more","computedAt":"2026-10-19T11:33:25.098Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"91517e70-b8e1-4349-aa06-8b54cf6237a1","entityName":"ELMAK","sourceName":"OFAC SDN","designatedAt":null,"sanctionType":null}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":100}}}