{"id":"a036ec6d-ec21-47ef-aded-c8b50429e924","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":false,"observedAt":"2026-09-14T09:26:02.574Z","confirmedAt":"2026-09-16T13:30:26.784Z","supersededAt":"2026-09-16T14:40:10.488Z","company":{"id":"365edbbc-56c7-4efe-be91-8a3e6b0ad554","name":"ELMEC TRADE OU"},"previous":null,"next":{"id":"55b46264-becc-47af-8a5d-73a7fbd91587","value":"Designated itself, so blocked","observedAt":"2026-09-16T14:40:10.488Z","supersededAt":"2026-09-17T11:31:12.034Z"},"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":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":"ELMEC TRADE OU","number":"14291975","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":"blocked","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":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":null,"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: ELMEC TRADE OU (US Consolidated Screening List)."],"outcome":"designated","subject":{"number":"14291975","entityId":"365edbbc-56c7-4efe-be91-8a3e6b0ad554","countryId":"EE","entityName":"ELMEC TRADE OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"844bec325b4fd851d4ecf92d10c138439813c2a0d1d85014afc503f3c70f015d","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":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","textsReadOn":"2026-09-13"},"statement":"The company is itself listed under this regime, and blocked as a listed party rather than through its owners.","threshold":"50% or more","computedAt":"2026-09-14T09:26:02.574Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"ELMEC TRADE OU","number":"14291975","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"365edbbc-56c7-4efe-be91-8a3e6b0ad554","entityName":"ELMEC TRADE OU","sourceName":"OFAC SDN","designatedAt":null},{"kind":"export_control","test":null,"regime":"US CSL (EL)","status":"not_verified","program":"Entity List (EL) - Bureau of Industry and Security","entityId":"365edbbc-56c7-4efe-be91-8a3e6b0ad554","entityName":"ELMEC TRADE OU","sourceName":"US Consolidated Screening List","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}