{"id":"cc76cdaa-9dea-4128-b62a-53fd66c1e4e6","test":"UK ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:33:54.933Z","confirmedAt":"2026-10-25T11:33:46.799Z","supersededAt":null,"company":{"id":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","name":"DONCOALTRADE SP Z O O"},"previous":{"id":"2d9f3512-0aca-4943-85b3-be125058bc98","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:33:43.290Z","supersededAt":"2026-09-18T11:33:54.933Z"},"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"UK 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":[{"share":null,"detail":"The KRS struck this company off the register on 26.11.2024, so it publishes no current holders for it.","reason":"not_found_in_register","company":{"name":"DONCOALTRADE SP Z O O","number":"0000421465","countryId":"PL"},"holderName":null}],"total":1,"byReason":{"not_found_in_register":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-14T19:10:36.796Z","source":"UK Sanctions List (FCDO)","publishedAt":"2026-09-11T00:00:00.000Z","publishedAtBasis":"stated_in_file"},{"readAt":"2026-09-13T14:36:27.699Z","source":"UK OFSI Consolidated List","publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date"}],"registers":[{"readAt":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":null,"publishedAtBasis":null}]},"caveats":["Holdings of different designated persons are not added together unless the shares are subject to a joint arrangement between them or one controls the rights of another.","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: DONCOALTRADE SP Z O O (US Consolidated Screening List)."],"outcome":"no_designated_holder_found","subject":{"number":"0000421465","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","countryId":"PL","entityName":"DONCOALTRADE SP Z O O"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"4fe8462afe2bcb8d589b970cce009acca893c1ddabf1d21b3959400525486645","citations":[{"url":"https://www.gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance","title":"OFSI, UK financial sanctions general guidance (updated 12 May 2026)","where":"Section 4.1 (more than 50% of shares or voting rights, or control), 4.1.3 (a designated person owns what it owns jointly with another) and 4.1.4 (holdings of different designated persons not simply aggregated)"},{"url":"https://www.legislation.gov.uk/uksi/2019/855/schedule/1","title":"The Russia (Sanctions) (EU Exit) Regulations 2019, Schedule 1","where":"Paragraph 2 (each joint holder of a share is treated as holding that share), paragraph 3 (joint arrangements), paragraph 4 (more than 50% of share capital), paragraph 9 (indirect holding through a chain of majority stakes). Each UK regulation this test is applied under was read, and carries the same definition and rules."}],"ruleTable":{"fingerprint":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","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":"more than 50%","computedAt":"2026-09-18T11:33:54.933Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"DONCOALTRADE SP Z O O","number":"0000421465","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"UKRAINE-EO13660","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","entityName":"DONCOALTRADE SP Z O O","sourceName":"OFAC SDN","designatedAt":null},{"kind":"export_control","test":null,"regime":"US CSL (EL)","status":"not_verified","program":"Entity List (EL) - Bureau of Industry and Security","entityId":"a28ac8ff-3703-4aed-a794-a4bfb997fad1","entityName":"DONCOALTRADE SP Z O O","sourceName":"US Consolidated Screening List","designatedAt":"2018-02-16T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}