{"id":"74ea5cf7-e4bc-4c4b-9844-8955a4354b4b","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 3 points","current":false,"observedAt":"2026-09-17T11:35:51.671Z","confirmedAt":"2026-09-17T11:35:51.671Z","supersededAt":"2026-09-18T11:36:08.593Z","company":{"id":"fe552d6f-3f04-4e38-aad5-9463c4333454","name":"ALLIANCE CAPITAL KS SP Z O O"},"previous":{"id":"8ba2e98d-1f9b-42f1-8ebc-a81c3970b417","value":"No designated holder found where the chain could be followed; it breaks at 3 points","observedAt":"2026-09-16T14:46:08.397Z","supersededAt":"2026-09-17T11:35:51.671Z"},"next":{"id":"6f56325a-c480-4db0-8f47-a14f6acb79a9","value":"No designated holder found where the chain could be followed; it breaks at 3 points","observedAt":"2026-09-18T11:36:08.593Z","supersededAt":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":65,"detail":"The holders the KRS lists hold 35% of the capital. The other 65% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"holderName":null},{"share":10,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","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":"2026-09-17T11:35:51.672Z","earliest":"2026-09-17T11:35:51.672Z"},"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":"no_designated_holder_found","subject":{"number":"7010994804","entityId":"fe552d6f-3f04-4e38-aad5-9463c4333454","countryId":"PL","entityName":"ALLIANCE CAPITAL KS SP Z O O"},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"b2c4f9acd8dfc9aef292ec8446ff28fe13b2b3415ebf96d740c6110de24092eb","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 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 35% 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":"2026-09-17T11:35:51.671Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"UK ownership and control","regime":"UK OFSI","status":"rule_verified","program":"Russia","entityId":"fe552d6f-3f04-4e38-aad5-9463c4333454","entityName":"ALLIANCE CAPITAL KS SP Z O O","sourceName":"UK Sanctions List (FCDO)","designatedAt":"2026-02-24T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":35}}}