{"id":"b517f4db-86b6-4564-9898-3cd380dd404e","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:32:45.637Z","confirmedAt":"2026-10-26T11:32:58.832Z","supersededAt":null,"company":{"id":"7285554d-2d7f-461d-9b2c-e226c7f84a61","name":"SIA INTER RAO Latvia"},"previous":{"id":"e41219d1-26c8-4f10-a996-824f9b8ba29a","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:32:36.103Z","supersededAt":"2026-09-18T11:32:45.637Z"},"next":null,"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":100,"detail":"AB INTER RAO Lietuva is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA INTER RAO Latvia","number":"40103268639","countryId":"LV"},"holderName":"AB INTER RAO Lietuva"}],"total":1,"byReason":{"holder_without_number":1}},"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":"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":["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: SIA INTER RAO Latvia (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"40103268639","entityId":"7285554d-2d7f-461d-9b2c-e226c7f84a61","countryId":"LV","entityName":"SIA INTER RAO Latvia"},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"926f5f4f93b0e6e6c59f529dc3bc7be58facec275df966d0802ce626537afecb","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 1 point, and past a break nothing is known.","threshold":"50% or more","computedAt":"2026-09-18T11:32:45.637Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA INTER RAO Latvia","number":"40103268639","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi; kapitāldaļas","entityId":"7285554d-2d7f-461d-9b2c-e226c7f84a61","entityName":"SIA INTER RAO Latvia","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}