{"id":"bb04e4f2-8e56-436f-98d4-cb4c4e6b970b","test":"OFAC 50 percent rule","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-18T11:30:31.217Z","confirmedAt":"2026-10-25T11:30:30.486Z","supersededAt":null,"company":{"id":"1267e702-1fd6-4f90-babd-fdc11062a523","name":"Skyparts INC OU"},"previous":{"id":"3107fa2d-09b4-4602-8460-e7877099fbb6","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-17T11:30:26.859Z","supersededAt":"2026-09-18T11:30:31.217Z"},"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":[],"total":0,"byReason":{}},"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":"2026-09-14T08:59:17.203Z","source":"Estonia e-Business Register (shareholders)","publishedAt":"2026-09-13T09:20:29.000Z","holdingsReadAt":{"latest":"2026-09-14T08:58:29.708Z","earliest":"2026-09-14T08:58:29.708Z"},"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 holder shares a name with a designated party. A name alone is not counted."],"outcome":"no_designated_holder_found","subject":{"number":"14720672","entityId":"1267e702-1fd6-4f90-babd-fdc11062a523","countryId":"EE","entityName":"Skyparts INC OU"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"22c91d012a46a46cc1288527a4f036f9b01c87975f9ed1cf841bef332f485ca1","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 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":"50% or more","computedAt":"2026-09-18T11:30:31.217Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Skyparts INC OU","number":"14720672","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"UK ownership and control","regime":"UK OFSI","status":"rule_verified","program":"Russia","entityId":"1267e702-1fd6-4f90-babd-fdc11062a523","entityName":"Skyparts INC OU","sourceName":"UK Sanctions List (FCDO)","designatedAt":"2024-11-07T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":1,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":100}}}