{"id":"c42a16c4-db67-4220-8e85-053c75b28d51","test":"Swiss ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-17T11:34:51.253Z","confirmedAt":"2026-09-17T11:34:51.253Z","supersededAt":"2026-09-18T11:35:04.116Z","company":{"id":"d3867fb4-11fa-4324-9f4d-ab941e9de320","name":"SIA \"RIGA YACHT MARINA\""},"previous":null,"next":{"id":"20d94071-1727-4a99-a43c-647f5a08fe42","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-18T11:35:04.116Z","supersededAt":null},"derivation":{"kind":"ownership_verdict","path":[],"test":"Swiss ownership and control","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":"2026-09-16T22:01:40.056Z","source":"Switzerland SECO Sanctions List","publishedAt":"2026-09-04T00:00:00.000Z","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":["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."],"outcome":"no_designated_holder_found","subject":{"number":"40203003020","entityId":"d3867fb4-11fa-4324-9f4d-ab941e9de320","countryId":"LV","entityName":"SIA \"RIGA YACHT MARINA\""},"holdings":{"total":3,"heldByCompanies":0,"notPublishedAsCompanies":3},"identity":"f85852075b90602c3ecf9e51d2072fe6b25fd5e70581845c70ca22d6e6728487","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":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","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 3 holdings 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":"2026-09-17T11:34:51.253Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"No designated company appears anywhere in the chain the registers state. Natural persons in the chain were compared with designated persons by name only.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":3,"masked":0,"directShareOfSubject":100}}}