{"id":"b91bd896-4361-4370-bed6-af5b4e59d9e8","test":"Swiss ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-25T20:31:02.542Z","confirmedAt":"2026-10-25T11:32:46.726Z","supersededAt":null,"company":{"id":"776acdaa-8b67-4793-be63-d9cb0def8151","name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"previous":{"id":"381c3e3b-05af-42a8-9335-6ce8c5fbccd2","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:32:52.512Z","supersededAt":"2026-09-25T20:31:02.542Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"Swiss ownership and control","notes":["Sabiedrība ar ierobežotu atbildību \"RAPIRA\" holds 50% of itself. Own shares carry no owner to follow and are left out of the chain; percentages are not re-based around them.","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":{}},"change":{"was":"No designated company found in the chain; the people in it are compared by name only","from":"381c3e3b-05af-42a8-9335-6ce8c5fbccd2","lines":["Listed now: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" on Australia DFAT Consolidated List (Australia DFAT, Autonomous (Russia))"],"causes":["list"],"answerChanged":false},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-23T22:17:26.953Z","source":"Switzerland SECO Sanctions List","publishedAt":"2026-09-04T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":"2026-09-19T10:30:34.868Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-18T20:25:35.000Z","holdingsReadAt":{"latest":"2026-09-19T10:30:00.011Z","earliest":"2026-09-19T10:30:00.011Z"},"publishedAtBasis":"server_last_modified"}]},"caveats":["What owning and controlling mean is set out in SECO's guidance on the sanctions ordinances, which SECO says is not legally binding.","SECO adds the holdings of several sanctioned parties together \"in principle\" (grundsätzlich).","Control raises a presumption that the company may rebut case by case.","SECO counts holdings held directly or indirectly, and publishes no worked example with percentages. A company owned at the threshold is treated as holding its own shares for the listed party, as under the EU test.","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 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: Sabiedrība ar ierobežotu atbildību \"RAPIRA\" (Australia DFAT Consolidated List)."],"outcome":"no_designated_holder_found","subject":{"number":"40103322761","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","countryId":"LV","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\""},"holdings":{"total":2,"heldByCompanies":1,"notPublishedAsCompanies":1},"identity":"6371807218b74e79e7dc6b06e3781e7b2cc6bc5d41382e390eb603ae703aa92b","citations":[{"url":"https://www.seco.admin.ch/dam/de/sd-web/Vjbtwu26yOgQ/Auslegungshilfe%20f%C3%BCr%20Sanktionsmassnahmen.pdf","title":"SECO, Auslegungshilfe Sanktionsmassnahmen (Stand 30. Juni 2026)","where":"Chapter 1, which applies to every sanctions ordinance that freezes funds: 1.10 (owning: 50% or more of the ownership interests, directly or indirectly; the interests of several sanctioned parties added together in principle) and 1.11 (control: any one of criteria a to h, unless the contrary is shown in the case)"},{"url":"https://www.fedlex.admin.ch/","title":"The Swiss sanctions ordinances in SWISS_ORDINANCES_READ, as consolidated on fedlex","where":"The freeze article of each, which freezes the funds and economic resources owned or controlled by the listed parties, by parties acting on their behalf, and by companies and organisations those parties own or control"}],"ruleTable":{"fingerprint":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","signedOffOn":"2026-09-17","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 50% 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":"50% or more","computedAt":"2026-09-25T20:31:02.542Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","number":"40103322761","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Australia DFAT","status":"not_verified","program":"Autonomous (Russia)","entityId":"776acdaa-8b67-4793-be63-d9cb0def8151","entityName":"Sabiedrība ar ierobežotu atbildību \"RAPIRA\"","sourceName":"Australia DFAT Consolidated List","designatedAt":null,"sanctionType":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":50}}}