{"id":"a7fa8374-d169-4ce9-aba3-22f588960448","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-15T11:32:16.422Z","confirmedAt":"2026-09-16T13:31:39.556Z","supersededAt":"2026-09-16T14:44:45.642Z","company":{"id":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","name":"SIA FALCON INTERNATIONAL GROUP"},"previous":{"id":"3e49319d-16ea-4428-8384-48369758cffd","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-14T09:27:33.033Z","supersededAt":"2026-09-15T11:32:16.422Z"},"next":{"id":"c5ea5c7f-6513-414e-be09-01ec8af01bd3","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-16T14:44:45.642Z","supersededAt":"2026-09-17T11:34:44.978Z"},"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","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":[],"total":0,"byReason":{}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-14T19:10:36.796Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-11T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-09-13T14:36:27.699Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"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":["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.","1 holder shares a name with a designated party. A name alone is not counted. The birth date the register publishes agrees with the designated person's for that holder (to the month). A birth date is not counted either."],"outcome":"no_designated_holder_found","subject":{"number":"45403041088","entityId":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","countryId":"LV","entityName":"SIA FALCON INTERNATIONAL GROUP"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"af3d360d01b22abed2ed755e9a8eea8b1f5ac8297c567ad9f78e6a7f011e9eb2","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":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","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 100% 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":"more than 50%","computedAt":"2026-09-15T11:32:16.422Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"SIA FALCON INTERNATIONAL GROUP","number":"45403041088","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"DPRK","entityId":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","entityName":"SIA FALCON INTERNATIONAL GROUP","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":1,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":100}}}