{"id":"842e71b7-1605-48c4-9908-20681b6b0514","test":"OFAC 50 percent rule","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-25T20:31:02.542Z","confirmedAt":"2026-10-26T11:33:07.073Z","supersededAt":null,"company":{"id":"776acdaa-8b67-4793-be63-d9cb0def8151","name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"previous":{"id":"401d260a-2c93-463f-b374-4bc65234fd07","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:32:52.512Z","supersededAt":"2026-09-25T20:31:02.542Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["Sabiedrība ar ierobežotu atbildību \"RAPIRA\" holds 50% of itself. Own shares carry no owner to follow and are left out of the chain; percentages are not re-based around them.","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":{}},"change":{"was":"No designated company found in the chain; the people in it are compared by name only","from":"401d260a-2c93-463f-b374-4bc65234fd07","lines":["Listed now: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" on Australia DFAT Consolidated List (Australia DFAT, Autonomous (Russia))"],"causes":["list"],"answerChanged":false},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-22T10:50:48.706Z","source":"OFAC SDN","publishedAt":"2026-09-18T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":"2026-09-19T10:30:34.868Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-18T20:25:35.000Z","holdingsReadAt":{"latest":"2026-09-19T10:30:00.011Z","earliest":"2026-09-19T10:30:00.011Z"},"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: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" (Australia DFAT Consolidated List)."],"outcome":"no_designated_holder_found","subject":{"number":"40103322761","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"holdings":{"total":2,"heldByCompanies":1,"notPublishedAsCompanies":1},"identity":"8b867378b5abb4c85ae591abf6b2a6b8dedadc0f907cef8b9940120163b4087f","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 company listed under this regime holds any share of the company, anywhere in the chain the registers state. Natural persons hold one holding in the chain, including 50% of the company directly. 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":"2026-09-25T20:31:02.542Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","number":"40103322761","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Australia DFAT","status":"not_verified","program":"Autonomous (Russia)","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","sourceName":"Australia DFAT Consolidated List","designatedAt":null,"sanctionType":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":50}}}