{"id":"7e81a054-011e-4766-9b69-cb2130ecea91","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-17T11:33:47.972Z","confirmedAt":"2026-09-17T11:33:47.972Z","supersededAt":"2026-09-18T11:33:59.586Z","company":{"id":"a5aade93-754a-4618-9989-50b92e80d897","name":"SIA \"Proficom\""},"previous":{"id":"963911aa-70dd-4db2-b8f0-cf8bcbda71fd","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:43:36.277Z","supersededAt":"2026-09-17T11:33:47.972Z"},"next":{"id":"df4c86a3-7ec3-4937-9080-e49370d8a7d0","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-18T11:33:59.586Z","supersededAt":"2026-09-25T20:31:26.980Z"},"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":"TRANS FACTOR HOLDINGS LIMITED is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"Proficom\"","number":"40103199479","countryId":"LV"},"holderName":"TRANS FACTOR HOLDINGS 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 \"Proficom\" (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"40103199479","entityId":"a5aade93-754a-4618-9989-50b92e80d897","countryId":"LV","entityName":"SIA \"Proficom\""},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"6a088ef52bdeab9f4874481e70c71ea230f746b1f853a904cc0e73cf4faf1796","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 1 point, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-17T11:33:47.972Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA \"Proficom\"","number":"40103199479","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Nekustamais īpašums","entityId":"a5aade93-754a-4618-9989-50b92e80d897","entityName":"SIA \"Proficom\"","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}