{"id":"76c0381e-446d-45bf-9d97-308935b2ffcd","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-18T11:32:35.190Z","confirmedAt":"2026-10-26T11:32:48.027Z","supersededAt":null,"company":{"id":"6b8659b5-f66e-4384-89b8-0ffa260c7330","name":"Eastline Technologies OÜ"},"previous":{"id":"9c387be7-0f48-47fe-a402-fe6223f65604","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-17T11:32:25.755Z","supersededAt":"2026-09-18T11:32:35.190Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","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":"2026-09-14T19:10:36.796Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-11T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-09-13T14:36:27.699Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"registers":[{"readAt":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":{"latest":"2026-09-14T08:58:29.708Z","earliest":"2026-09-14T08:58:29.708Z"},"publishedAtBasis":"server_last_modified"}]},"caveats":["Holdings of different designated persons are not added together unless the shares are subject to a joint arrangement between them or one controls the rights of another.","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: Eastline Technologies OÜ (US Consolidated Screening List)."],"outcome":"no_designated_holder_found","subject":{"number":"11195366","entityId":"6b8659b5-f66e-4384-89b8-0ffa260c7330","countryId":"EE","entityName":"Eastline Technologies OÜ"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"90a0e9b788138907d54646fffe14163f5ae9cae02a82cda09624cfaaa80261ee","citations":[{"url":"https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance","title":"OFSI, UK financial sanctions general guidance (updated 12 May 2026)","where":"Section 4.1 (more than 50% of shares or voting rights, or control), 4.1.3 (a designated person owns what it owns jointly with another) and 4.1.4 (holdings of different designated persons not simply aggregated)"},{"url":"https://www.legislation.gov.uk/uksi/2019/855/schedule/1","title":"The Russia (Sanctions) (EU Exit) Regulations 2019, Schedule 1","where":"Paragraph 2 (each joint holder of a share is treated as holding that share), paragraph 3 (joint arrangements), paragraph 4 (more than 50% of share capital), paragraph 9 (indirect holding through a chain of majority stakes). Each UK regulation this test is applied under was read, and carries the same definition and rules."}],"ruleTable":{"fingerprint":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","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":"more than 50%","computedAt":"2026-09-18T11:32:35.190Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"Eastline Technologies OÜ","number":"11195366","countryId":"EE"},"listings":[{"kind":"export_control","test":null,"regime":"US CSL (DPL)","status":"not_verified","program":"Denied Persons List (DPL) - Bureau of Industry and Security","entityId":"6b8659b5-f66e-4384-89b8-0ffa260c7330","entityName":"Eastline Technologies OÜ","sourceName":"US Consolidated Screening List","designatedAt":"2022-03-09T00:00:00.000Z"},{"kind":"export_control","test":null,"regime":"US CSL (EL)","status":"not_verified","program":"Entity List (EL) - Bureau of Industry and Security","entityId":"6b8659b5-f66e-4384-89b8-0ffa260c7330","entityName":"Eastline Technologies OÜ","sourceName":"US Consolidated Screening List","designatedAt":"2022-03-09T00:00:00.000Z"}]}],"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}}}