{"id":"e765f1d9-d3de-4f1b-94e1-56d5cdce1486","test":"UK ownership and control","value":"No designated holder found where the chain could be followed; it breaks at 1 point","current":false,"observedAt":"2026-09-14T09:26:28.509Z","confirmedAt":"2026-09-16T13:30:47.629Z","supersededAt":"2026-09-16T14:41:33.519Z","company":{"id":"624f862f-8a3a-46aa-b3cf-720558d6d664","name":"VENTSPILS ATTISTIBAS AGENTURA"},"previous":null,"next":{"id":"6ec2146f-a00b-4fff-838e-7e10d748f1be","value":"No designated holder found where the chain could be followed; it breaks at 1 point","observedAt":"2026-09-16T14:41:33.519Z","supersededAt":"2026-09-17T11:32:11.516Z"},"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":"Latvia Enterprise Register (members) 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":"VENTSPILS ATTISTIBAS AGENTURA","number":"40008033300","countryId":"LV"},"holderName":null}],"total":1,"byReason":{"no_holders_published":1}},"effect":null,"inputs":{"lists":[{"readAt":"2026-09-13T15:07:31.157Z","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":"2026-09-14T08:59:58.987Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-13T20:25:36.000Z","holdingsReadAt":null,"publishedAtBasis":"server_last_modified"}]},"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":"no_designated_holder_found","subject":{"number":"40008033300","entityId":"624f862f-8a3a-46aa-b3cf-720558d6d664","countryId":"LV","entityName":"VENTSPILS ATTISTIBAS AGENTURA"},"holdings":{"total":0,"heldByCompanies":0,"notPublishedAsCompanies":0},"identity":"d6787103a894dffb5ec83da01fa72d058c6e3a8370db094894904afc3a22aa08","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":"6354cf1089ca4c64b6f5b5edcf30e2402a1db672daa68a8b04f79a2c0e4ef5b8","signedOffOn":"2026-09-13","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":"2026-09-14T09:26:28.509Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":false,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"VENTSPILS ATTISTIBAS AGENTURA","number":"40008033300","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"GLOMAG","entityId":"624f862f-8a3a-46aa-b3cf-720558d6d664","entityName":"VENTSPILS ATTISTIBAS AGENTURA","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":0,"masked":0,"directShareOfSubject":0}}}