{"id":"c667fa59-084b-4ef7-9328-dc8ca5e755cb","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-17T11:35:08.399Z","confirmedAt":"2026-09-17T11:35:08.399Z","supersededAt":"2026-09-18T11:35:21.944Z","company":{"id":"df5b003c-fd68-47e9-9d36-2d6b0c556782","name":"Fonds \"Aven Foundation\""},"previous":{"id":"af28458c-1152-4508-8f13-95ca6d30ff39","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:45:13.454Z","supersededAt":"2026-09-17T11:35:08.399Z"},"next":{"id":"545bbed8-eba7-4449-80eb-629723a71c4e","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-18T11:35:21.944Z","supersededAt":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":null,"detail":"Latvia Enterprise Register (members) holds no shareholder rows for this company. Neither Baltic register publishes the shareholders of a joint-stock company, so this is not evidence that it has none.","reason":"no_holders_published","company":{"name":"Fonds \"Aven Foundation\"","number":"40008302411","countryId":"LV"},"holderName":null}],"total":1,"byReason":{"no_holders_published":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":null,"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: Fonds \"Aven Foundation\" (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"40008302411","entityId":"df5b003c-fd68-47e9-9d36-2d6b0c556782","countryId":"LV","entityName":"Fonds \"Aven Foundation\""},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"2a816529804613f8a0a2099ad360f65e76258655f50b65b6cf98130916bb4f22","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":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","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":"2026-09-17T11:35:08.399Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"Fonds \"Aven Foundation\"","number":"40008302411","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi; kapitāldaļas; nekustamie īpašumi","entityId":"df5b003c-fd68-47e9-9d36-2d6b0c556782","entityName":"Fonds \"Aven Foundation\"","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}}}