{"id":"96a44058-32a5-4069-b636-6b11f1299a22","test":"EU owning or controlling","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-14T09:26:32.122Z","confirmedAt":"2026-09-16T13:30:50.725Z","supersededAt":"2026-09-16T14:41:44.734Z","company":{"id":"681b63cf-c704-4cd1-b5c3-3f29549924e7","name":"FREE SKY SOLUTIONS OU"},"previous":null,"next":{"id":"ced13549-99c9-440c-80df-717794ef0b92","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:41:44.734Z","supersededAt":"2026-09-17T11:32:20.852Z"},"derivation":{"kind":"ownership_verdict","path":[],"test":"EU owning or controlling","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":"Estonia e-Business Register (shareholders) holds no shareholder rows for this company. Neither Baltic register publishes the shareholders of a joint-stock company, so this is not evidence that it has none.","reason":"no_holders_published","company":{"name":"FREE SKY SOLUTIONS OU","number":"EE102381957","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-13T14:34:50.281Z","source":"EU Consolidated Sanctions List","publishedAt":"2026-08-05T14:47:04.449Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":null,"publishedAtBasis":"server_last_modified"}]},"caveats":["Ownership raises a presumption that the listed person controls the entity and its assets. The entity may rebut it case by case.","The definition applied here was read in Regulation 269/2014. Listings under other EU legal acts are not assessed with it.","The Commission says control over an entity also reaches that entity's own subsidiaries, but publishes no worked example with percentages. A company owned at the threshold is treated as holding its own shares for the listed person on that basis.","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":"EE102381957","entityId":"681b63cf-c704-4cd1-b5c3-3f29549924e7","countryId":"EE","entityName":"FREE SKY SOLUTIONS OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"eadc9d720a0fc0a3c1eac38bac3ea2398b5e3514a4242106fc29ed7a18402a63","citations":[{"url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2037","title":"Council Regulation (EU) No 269/2014, Article 1, as amended by Council Regulation (EU) 2025/2037 of 23 October 2025","where":"Article 1, points (i) \"owning\": 50% or more of the proprietary rights, and (j) \"controlling\""},{"url":"https://finance.ec.europa.eu/system/files/2023-07/faqs-sanctions-russia-assets-freezes_en.pdf","title":"European Commission, Frequently asked questions: asset freeze under Council Regulation 269/2014 (as of 6 May 2026)","where":"Question 1 (presumption that control extends to the assets of an owned or controlled entity, rebuttable), Question 8 (aggregated ownership of several listed persons) and Question 9 (control over one entity reaches its own subsidiaries)"}],"ruleTable":{"fingerprint":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","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":"2026-09-14T09:26:32.122Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"FREE SKY SOLUTIONS OU","number":"EE102381957","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"681b63cf-c704-4cd1-b5c3-3f29549924e7","entityName":"FREE SKY SOLUTIONS OU","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}