{"id":"a847c40d-ed3a-4681-b8c6-8aac2e0e4044","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 4 points","current":true,"observedAt":"2026-09-18T11:30:36.827Z","confirmedAt":"2026-10-25T11:30:36.078Z","supersededAt":null,"company":{"id":"15ed5cf2-4c4f-4ec3-8ea4-df33740f0dfe","name":"K Dystrybucja Sp. z o.o."},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["4 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":25,"detail":null,"reason":"holder_name_masked","company":{"name":"K Dystrybucja Sp. z o.o.","number":"0000965303","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"K Dystrybucja Sp. z o.o.","number":"0000965303","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"K Dystrybucja Sp. z o.o.","number":"0000965303","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"K Dystrybucja Sp. z o.o.","number":"0000965303","countryId":"PL"},"holderName":null}],"total":4,"byReason":{"holder_name_masked":4}},"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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:30:36.828Z","earliest":"2026-09-18T11:30:36.828Z"},"publishedAtBasis":null}]},"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: K Dystrybucja Sp. z o.o. (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000965303","entityId":"15ed5cf2-4c4f-4ec3-8ea4-df33740f0dfe","countryId":"PL","entityName":"K Dystrybucja Sp. z o.o."},"holdings":{"total":4,"heldByCompanies":0,"notPublishedAsCompanies":4},"identity":"76132e711eb57de1e10ee88b22c9af39b34cc63788f6a834c88d047ab729953b","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":"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 4 points, and past a break nothing is known. Natural persons hold 4 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":"50% or more","computedAt":"2026-09-18T11:30:36.827Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"K Dystrybucja Sp. z o.o.","number":"0000965303","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"wykluczenie z postępowania o udzielenie zamówienia publicznego lub konkursu","entityId":"15ed5cf2-4c4f-4ec3-8ea4-df33740f0dfe","entityName":"K Dystrybucja Sp. z o.o.","sourceName":"Poland MSWiA sanctions list","designatedAt":"2022-04-26T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":4,"masked":4,"directShareOfSubject":100}}}