{"id":"7944c9d0-3001-454d-b7b6-7437cc0102a2","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-16T14:45:48.005Z","confirmedAt":"2026-09-16T14:45:48.005Z","supersededAt":"2026-09-17T11:35:35.063Z","company":{"id":"f2229bdc-113e-4e0b-be0b-eda090cad5de","name":"SIA \"TransBaltic OIL\""},"previous":{"id":"fc310f8d-3b3a-4007-ab0a-4babf1e10b0a","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-14T09:27:55.105Z","supersededAt":"2026-09-16T14:45:48.005Z"},"next":{"id":"a3bdfddd-f787-424e-9008-8b32a1c87a61","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:35:35.063Z","supersededAt":"2026-09-18T11:35:50.842Z"},"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","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":100,"detail":"BNK (UK) Limited is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"TransBaltic OIL\"","number":"40103552058","countryId":"LV"},"holderName":"BNK (UK) Limited"}],"total":1,"byReason":{"holder_without_number":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":"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":["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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: SIA \"TransBaltic OIL\" (Latvia FID frozen assets register).","1 holder shares a name with a designated party. A name alone is not counted."],"outcome":"no_designated_holder_found","subject":{"number":"40103552058","entityId":"f2229bdc-113e-4e0b-be0b-eda090cad5de","countryId":"LV","entityName":"SIA \"TransBaltic OIL\""},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"a65c7cd09d6e473e3ee5d1c24930f8b771082930491f79c4a7f5967f69c87ea2","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":"8826482c6e3d3ac72d2b2edf419a0b09ba86883deafffb9cccd0a38fcf649b4c","signedOffOn":"2026-09-15","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 1 point, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-16T14:45:48.005Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA \"TransBaltic OIL\"","number":"40103552058","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi; kapitāldaļas","entityId":"f2229bdc-113e-4e0b-be0b-eda090cad5de","entityName":"SIA \"TransBaltic OIL\"","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":1,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}