{"id":"cdddea49-4950-4e8b-b097-a26bc31490ff","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:33:30.386Z","confirmedAt":"2026-10-26T11:33:59.565Z","supersededAt":null,"company":{"id":"916eef31-7dc0-410f-882f-063e416b3780","name":"SIA \"Seagull Investments\""},"previous":{"id":"6fca221b-7f0e-4c14-a2c2-462372b98f13","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-17T11:33:19.241Z","supersededAt":"2026-09-18T11:33:30.386Z"},"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":[{"share":100,"detail":"VIVIGA LIMITED is published without a registration number or a country, so the chain cannot continue past it.","reason":"holder_without_number","company":{"name":"SIA \"Seagull Investments\"","number":"40103711920","countryId":"LV"},"holderName":"VIVIGA LIMITED"}],"total":1,"byReason":{"holder_without_number":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":{"latest":"2026-09-14T21:53:47.938Z","earliest":"2026-09-14T21:53:47.938Z"},"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: SIA \"Seagull Investments\" (Latvia FID frozen assets register).","1 holder shares a name with a designated party. A name alone is not counted."],"outcome":"no_designated_holder_found","subject":{"number":"40103711920","entityId":"916eef31-7dc0-410f-882f-063e416b3780","countryId":"LV","entityName":"SIA \"Seagull Investments\""},"holdings":{"total":1,"heldByCompanies":1,"notPublishedAsCompanies":0},"identity":"161bc7fe565e2586c861ce0754f0377da3a59c961b6706158224d125cc5ac613","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 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":"2026-09-18T11:33:30.386Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA \"Seagull Investments\"","number":"40103711920","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Līdzekļi; kapitāldaļas; nekustamie īpašumi","entityId":"916eef31-7dc0-410f-882f-063e416b3780","entityName":"SIA \"Seagull Investments\"","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":1,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}