{"id":"d316ac77-27c8-4aae-bb6f-9b59b1a3706d","test":"OFAC 50 percent rule","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":true,"observedAt":"2026-09-18T11:34:17.302Z","confirmedAt":"2026-10-25T11:34:08.954Z","supersededAt":null,"company":{"id":"b3111036-3371-4646-9a8e-c478a41341e9","name":"KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.)"},"previous":null,"next":null,"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["1 natural-person holding is published with a masked name and was compared with nobody.","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":null,"reason":"holder_name_masked","company":{"name":"KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.)","number":"0000126355","countryId":"PL"},"holderName":null}],"total":1,"byReason":{"holder_name_masked":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":null,"source":"Poland KRS (current extract, read on demand)","publishedAt":null,"holdingsReadAt":{"latest":"2026-09-18T11:34:17.304Z","earliest":"2026-09-18T11:34:17.304Z"},"publishedAtBasis":null}]},"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: KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.) (Poland MSWiA sanctions list)."],"outcome":"no_designated_holder_found","subject":{"number":"0000126355","entityId":"b3111036-3371-4646-9a8e-c478a41341e9","countryId":"PL","entityName":"KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.)"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"b74b3fc166667553f53969dd4c08e1b5caa0edcfaf5bea5aa70fff081f732b7a","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. Natural persons hold one holding in the chain, including 100% of the company directly. The register publishes that person's name masked, so it was compared with no designated person.","threshold":"50% or more","computedAt":"2026-09-18T11:34:17.302Z","aggregation":"aggregated","chainComplete":false,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.)","number":"0000126355","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Poland","status":"not_verified","program":"wykluczenie z postępowania o udzielenie zamówienia publicznego lub konkursu","entityId":"b3111036-3371-4646-9a8e-c478a41341e9","entityName":"KASPERSKY Lab Polska Sp. z o.o. (obecnie: PILARZ CAPITAL Sp. z o.o.)","sourceName":"Poland MSWiA sanctions list","designatedAt":"2022-04-26T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":1,"directShareOfSubject":100}}}