{"id":"7f8d936a-8807-4d4a-95b6-c517a3832e9a","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:34:09.036Z","confirmedAt":"2026-10-26T11:34:37.797Z","supersededAt":null,"company":{"id":"acb1e9ed-6e47-4dc1-a0b9-38b3ea48e697","name":"EDELBIEV Baysangur"},"previous":null,"next":null,"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":null,"detail":"BAYSANGUR EDELBIEV is on the VAT white list without a KRS number, and only a subject registered in the KRS has its holders published there.","reason":"not_found_in_register","company":{"name":"EDELBIEV Baysangur","number":"147421934","countryId":"PL"},"holderName":null}],"total":1,"byReason":{"not_found_in_register":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":null,"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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: EDELBIEV Baysangur (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"147421934","entityId":"acb1e9ed-6e47-4dc1-a0b9-38b3ea48e697","countryId":"PL","entityName":"EDELBIEV Baysangur"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"ffd27dcf1e4b29f9ad687c6baf1206725de6aec4dd8d789fb0cd25ef545092b0","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":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","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":"2026-09-18T11:34:09.036Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"EDELBIEV Baysangur","number":"147421934","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"a. zamrożenie wszystkich środków finansowych i zasobów gospodarczych, b. zakaz udostępniania podmiotowi wpisanemu na listę lub na jego rzecz – bezpośrednio lub pośrednio – jakichko","entityId":"acb1e9ed-6e47-4dc1-a0b9-38b3ea48e697","entityName":"EDELBIEV Baysangur","sourceName":"Poland MSWiA sanctions list","designatedAt":"2023-05-30T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}