{"id":"8819ae36-8fc5-46a8-a9a0-bfd838aba5e2","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-17T11:34:09.719Z","confirmedAt":"2026-09-17T11:34:09.719Z","supersededAt":"2026-09-18T11:34:21.814Z","company":{"id":"b6a372f0-c275-45bd-abbc-122eea5fabe2","name":"SIA \"Severstal Distribution\""},"previous":{"id":"29f519b3-67d1-4128-a5d4-41e0c4139bc9","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:44:04.018Z","supersededAt":"2026-09-17T11:34:09.719Z"},"next":{"id":"3cec8c2d-6edb-47dc-870f-1c571946e288","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-18T11:34:21.814Z","supersededAt":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":100,"detail":"MARCEGAGLIA CARBON STEEL S.P.A. is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"Severstal Distribution\"","number":"40003001968","countryId":"LV"},"holderName":"MARCEGAGLIA CARBON STEEL S.P.A."}],"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."],"outcome":"no_designated_holder_found","subject":{"number":"40003001968","entityId":"b6a372f0-c275-45bd-abbc-122eea5fabe2","countryId":"LV","entityName":"SIA \"Severstal Distribution\""},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"e842fc05a60af4d72d034caf413e82d41a1c0d7e225c01a6815b467a68052678","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":"2026-09-17T11:34:09.719Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"No designated party was reached on the part of the chain that could be followed, which breaks at 1 point.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}