{"id":"803fe907-0129-463f-a94d-abaeb372c321","test":"Canadian deemed ownership","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-18T11:34:37.557Z","confirmedAt":"2026-10-24T12:19:22.200Z","supersededAt":null,"company":{"id":"c1361170-277c-4863-8324-893fb56c6e0d","name":"Sabiedrība ar ierobežotu atbildību \"ĶĪPSALA-ZUNDS\""},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"Canadian deemed ownership","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":"2026-09-17T10:47:29.329Z","source":"Canada Consolidated Autonomous Sanctions List","publishedAt":null,"publishedAtBasis":null}],"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 company is not listed itself. The Act deems what a company controlled by a listed person owns to be owned by that person, so dealing in the company's property is dealing in the listed person's.","The Act speaks of a person holding 50% or more. Neither the Act nor the guidance of Global Affairs Canada says whether the holdings of different listed persons are added together, so a result reached only by adding them goes to a reviewer.","Global Affairs Canada's guidance, which it says is general information and not legal advice, reads control widely: considerable influence over a company's strategic decisions is enough, and in one of its scenarios so is a listed person on the board of a company's owner.","The Act counts holdings held directly or indirectly, and deems what a controlled company owns, its own holdings included, to be the listed person's in full.","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":"50003125761","entityId":"c1361170-277c-4863-8324-893fb56c6e0d","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"ĶĪPSALA-ZUNDS\""},"holdings":{"total":4,"heldByCompanies":1,"notPublishedAsCompanies":3},"identity":"83109d2ccf60df1593b1e1a44fc18bc3e2adb1b32991e01904bc35975caaaa59","citations":[{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/FullText.html","title":"Special Economic Measures Act, S.C. 1992, c. 17, section 2.1 (added by S.C. 2023, c. 26, s. 253)","where":"Subsection 2.1(1): property owned, or held or controlled directly or indirectly, by an entity a person controls is deemed to be owned by that person. Subsection 2.1(2): the person controls the entity if (a) it holds, directly or indirectly, 50% or more of the shares or ownership interests or of the voting rights, (b) it can change the composition or powers of the board, or (c) it can direct the entity's activities by any means"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/J-2.3/FullText.html","title":"Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), S.C. 2017, c. 21, section 2.01","where":"The same deeming provision and criteria, for a foreign national listed under that Act"},{"url":"https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/faq.aspx?lang=eng","title":"Global Affairs Canada, Canadian sanctions: Frequently asked questions (modified 2026-08-14), and Canadian sanctions: Essential information (modified 2026-07-17)","where":"\"Can I deal with the subsidiaries of a designated company?\": the three criteria, a majority-owned subsidiary, and a subsidiary over whose strategic decision-making the parent has considerable influence; Essential information, scenario 3 (a listed person on the board of the buyer's owner)"},{"url":"https://laws-lois.justice.gc.ca/eng/acts/S-14.5/index.html","title":"The Canadian regulations in CANADA_REGULATIONS_APPLIED, as consolidated on Justice Laws","where":"The dealings ban of each, which forbids dealing in property a listed person owns, holds or controls"}],"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 3 holdings in the chain. 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":"50% or more","computedAt":"2026-09-18T11:34:37.557Z","aggregation":"not_settled","chainComplete":true,"jointHoldings":"not_settled","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":3,"masked":0,"directShareOfSubject":0}}}