{"id":"ac18fdf5-c558-486d-88bf-03dad86deb2a","test":"EU owning or controlling","value":"No designated holder found where the chain could be followed; it breaks at 2 points","current":false,"observedAt":"2026-09-14T09:26:09.686Z","confirmedAt":"2026-09-16T13:30:32.576Z","supersededAt":"2026-09-16T14:40:36.231Z","company":{"id":"42ef25b2-8f50-457b-966d-52e070a3b95a","name":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA"},"previous":null,"next":{"id":"3dbbbd16-4557-490f-9eda-2bce6f7c3189","value":"No designated holder found where the chain could be followed; it breaks at 2 points","observedAt":"2026-09-16T14:40:36.231Z","supersededAt":"2026-09-17T11:31:28.581Z"},"derivation":{"kind":"ownership_verdict","path":[],"test":"EU owning or controlling","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":50,"detail":null,"reason":"holder_name_masked","company":{"name":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA","number":"0001070994","countryId":"PL"},"holderName":null},{"share":50,"detail":null,"reason":"holder_name_masked","company":{"name":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA","number":"0001070994","countryId":"PL"},"holderName":null}],"total":2,"byReason":{"holder_name_masked":2}},"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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-14T09:26:09.687Z","earliest":"2026-09-14T09:26:09.687Z"},"publishedAtBasis":null}]},"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":"0001070994","entityId":"42ef25b2-8f50-457b-966d-52e070a3b95a","countryId":"PL","entityName":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA"},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"b75e014035646088f34e03a27f5d82b76c6fcdf63ad8dfb2ae166b177a6add7d","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 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":"50% or more","computedAt":"2026-09-14T09:26:09.686Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA","number":"0001070994","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"SDGT","entityId":"42ef25b2-8f50-457b-966d-52e070a3b95a","entityName":"CALLLYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA","sourceName":"OFAC SDN","designatedAt":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}}}