{"id":"c7c61c0a-7790-4794-95c1-2fd3a7163d11","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":false,"observedAt":"2026-09-17T11:31:15.498Z","confirmedAt":"2026-09-17T11:31:15.498Z","supersededAt":"2026-09-18T11:31:23.632Z","company":{"id":"38c9225a-a324-4c13-b540-b6aeb05fac00","name":"BY TRADE OU"},"previous":{"id":"00b08cc4-f5c2-4738-9d7c-3ac74c381740","value":"Designated itself, so blocked","observedAt":"2026-09-16T14:40:15.799Z","supersededAt":"2026-09-17T11:31:15.498Z"},"next":{"id":"4f9dcfd6-5e11-4c76-a6d6-dbe2df9440b3","value":"Designated itself, so blocked","observedAt":"2026-09-18T11:31:23.632Z","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":"Estonia e-Business Register (shareholders) 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":"BY TRADE OU","number":"12470521","countryId":"EE"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":"blocked","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":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."],"outcome":"designated","subject":{"number":"12470521","entityId":"38c9225a-a324-4c13-b540-b6aeb05fac00","countryId":"EE","entityName":"BY TRADE OU"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"8641ba0a286b80535413b3f2299b22527d36928967d98d3f0586e8a4d8e23b90","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":"The company is itself listed under this regime, and blocked as a listed party rather than through its owners.","threshold":"50% or more","computedAt":"2026-09-17T11:31:15.498Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"BY TRADE OU","number":"12470521","countryId":"EE"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"RUSSIA-EO14024","entityId":"38c9225a-a324-4c13-b540-b6aeb05fac00","entityName":"BY TRADE OU","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}