{"id":"81762080-8abb-497b-a2b4-2bb0b291f93e","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":true,"observedAt":"2026-09-18T11:31:28.758Z","confirmedAt":"2026-10-26T11:31:35.623Z","supersededAt":null,"company":{"id":"3c89b20f-2339-4087-840f-6792d2974c17","name":"MTZ BELARUS TRAKTOR sp. z o.o."},"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":5,"detail":"The holders the KRS lists hold 95% of the capital. The other 5% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"holderName":null},{"share":95,"detail":"BELARUS TRAKTOR KFT. is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"holderName":"BELARUS TRAKTOR KFT."}],"total":2,"byReason":{"unpublished_holders":1,"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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:31:28.759Z","earliest":"2026-09-18T11:31:28.759Z"},"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: MTZ BELARUS TRAKTOR sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000516323","entityId":"3c89b20f-2339-4087-840f-6792d2974c17","countryId":"PL","entityName":"MTZ BELARUS TRAKTOR sp. z o.o."},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"017eba3d70f6bf93a05aab69797e884f561d0796c4e2a8975aa7991839a36904","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 2 points, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-18T11:31:28.758Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"MTZ BELARUS TRAKTOR sp. z o.o.","number":"0000516323","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"a. zamrożenie funduszy zgromadzonych na rachunkach bankowych, b. zakaz świadomego i umyślnego udziału w działaniach, których celem lub skutkiem jest ominięcie środków wskazanych w ","entityId":"3c89b20f-2339-4087-840f-6792d2974c17","entityName":"MTZ BELARUS TRAKTOR sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2023-07-22T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}