{"id":"9c489096-59a9-4f07-886a-234b3bbd4085","test":"UK ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":true,"observedAt":"2026-10-19T11:33:25.098Z","confirmedAt":"2026-10-26T11:33:59.355Z","supersededAt":null,"company":{"id":"91517e70-b8e1-4349-aa06-8b54cf6237a1","name":"ELMAK"},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","notes":["2 natural-person holdings are published with a masked name and were compared with nobody.","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":51.01701951017019,"detail":null,"reason":"holder_name_masked","company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"holderName":null},{"share":48.98298048982981,"detail":null,"reason":"holder_name_masked","company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"holderName":null}],"total":2,"byReason":{"holder_name_masked":2}},"effect":null,"inputs":{"lists":[{"readAt":"2026-10-19T05:02:06.515Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-10-16T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-10-08T15:05:56.072Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-10-19T11:33:25.100Z","earliest":"2026-10-19T11:33:25.100Z"},"publishedAtBasis":null}]},"caveats":["Holdings of different designated persons are not added together unless the shares are subject to a joint arrangement between them or one controls the rights of another.","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":"0000113334","entityId":"91517e70-b8e1-4349-aa06-8b54cf6237a1","countryId":"PL","entityName":"ELMAK"},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"feeadc348c0759aa2a004bddf705489f0f56b047265c3e59537833e47afdd888","citations":[{"url":"https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance","title":"OFSI, UK financial sanctions general guidance (updated 12 May 2026)","where":"Section 4.1 (more than 50% of shares or voting rights, or control), 4.1.3 (a designated person owns what it owns jointly with another) and 4.1.4 (holdings of different designated persons not simply aggregated)"},{"url":"https://www.legislation.gov.uk/uksi/2019/855/schedule/1","title":"The Russia (Sanctions) (EU Exit) Regulations 2019, Schedule 1","where":"Paragraph 2 (each joint holder of a share is treated as holding that share), paragraph 3 (joint arrangements), paragraph 4 (more than 50% of share capital), paragraph 9 (indirect holding through a chain of majority stakes). Each UK regulation this test is applied under was read, and carries the same definition and rules."}],"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. Natural persons hold 2 holdings in the chain, including 100% of the company directly. The register publishes their names masked, so none of them was compared with any designated person.","threshold":"more than 50%","computedAt":"2026-10-19T11:33:25.098Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"ELMAK","number":"0000113334","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"91517e70-b8e1-4349-aa06-8b54cf6237a1","entityName":"ELMAK","sourceName":"OFAC SDN","designatedAt":null,"sanctionType":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":100}}}