{"id":"77658330-47ea-481a-87de-90e2bded02a1","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-17T11:33:38.193Z","confirmedAt":"2026-09-17T11:33:38.193Z","supersededAt":"2026-09-18T11:33:49.668Z","company":{"id":"9e7c50be-afec-4111-904c-011dfaeb93b7","name":"Sabiedrība ar ierobežotu atbildību \"OPTIMAX L\""},"previous":{"id":"668424de-e7c3-4763-8d6d-02f6acc91c2c","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-16T14:43:23.017Z","supersededAt":"2026-09-17T11:33:38.193Z"},"next":{"id":"0934f2a1-c9a6-4516-b5bf-a9f4f884c913","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:33:49.668Z","supersededAt":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":"2026-09-14T21:54:42.782Z","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":["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."],"outcome":"no_designated_holder_found","subject":{"number":"40003566687","entityId":"9e7c50be-afec-4111-904c-011dfaeb93b7","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"OPTIMAX L\""},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"60230fe668391958f6183858ab4f3444fae5432fd11b86d1dd3634c9d26a7dd6","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":"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 2 holdings 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":"2026-09-17T11:33:38.193Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","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":2,"masked":0,"directShareOfSubject":100}}}