{"id":"e68715c0-3a3f-4552-a801-61be4b34c80b","test":"UK ownership and control","value":"Designated itself, so frozen","current":false,"observedAt":"2026-09-17T11:35:51.671Z","confirmedAt":"2026-09-17T11:35:51.671Z","supersededAt":"2026-09-18T11:36:08.593Z","company":{"id":"fe552d6f-3f04-4e38-aad5-9463c4333454","name":"ALLIANCE CAPITAL KS SP Z O O"},"previous":{"id":"ab04af92-70ef-46f2-a9ed-4c2ef1d5cc3a","value":"Designated itself, so frozen","observedAt":"2026-09-16T14:46:08.397Z","supersededAt":"2026-09-17T11:35:51.671Z"},"next":{"id":"d61fed5a-5d5c-417c-a1f1-1cb33f136b9a","value":"Designated itself, so frozen","observedAt":"2026-09-18T11:36:08.593Z","supersededAt":null},"derivation":{"kind":"ownership_verdict","path":[],"test":"UK ownership and control","notes":["2 natural-person holdings are published with a masked name and were 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":65,"detail":"The holders the KRS lists hold 35% of the capital. The other 65% belongs to holders of under 10% each, whom the KRS does not publish.","reason":"unpublished_holders","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"holderName":null},{"share":10,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"holderName":null},{"share":25,"detail":null,"reason":"holder_name_masked","company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"holderName":null}],"total":3,"byReason":{"holder_name_masked":2,"unpublished_holders":1}},"effect":"frozen","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":{"latest":"2026-09-17T11:35:51.672Z","earliest":"2026-09-17T11:35:51.672Z"},"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."],"outcome":"designated","subject":{"number":"7010994804","entityId":"fe552d6f-3f04-4e38-aad5-9463c4333454","countryId":"PL","entityName":"ALLIANCE CAPITAL KS SP Z O O"},"holdings":{"total":2,"heldByCompanies":0,"notPublishedAsCompanies":2},"identity":"3c1ed8e1d893ea9611f9f85c3a107d072c24a5181571a54a9db0e9e7e027e34a","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":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","signedOffOn":"2026-09-17","textsReadOn":"2026-09-13"},"statement":"The company is itself listed under this regime, and frozen as a listed party rather than through its owners.","threshold":"more than 50%","computedAt":"2026-09-17T11:35:51.671Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"ALLIANCE CAPITAL KS SP Z O O","number":"7010994804","countryId":"PL"},"listings":[{"kind":"asset_freeze","test":"UK ownership and control","regime":"UK OFSI","status":"rule_verified","program":"Russia","entityId":"fe552d6f-3f04-4e38-aad5-9463c4333454","entityName":"ALLIANCE CAPITAL KS SP Z O O","sourceName":"UK Sanctions List (FCDO)","designatedAt":"2026-02-24T00:00:00.000Z"}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":2,"masked":2,"directShareOfSubject":35}}}