{"id":"f8a15495-a2a7-468f-9e13-06625d89afc0","test":"OFAC 50 percent rule","value":"No designated company found in the chain; the people in it are compared by name only","current":false,"observedAt":"2026-09-16T14:42:35.178Z","confirmedAt":"2026-09-16T14:42:35.178Z","supersededAt":"2026-09-17T11:33:00.608Z","company":{"id":"84f60c05-b230-434c-973c-e0f0152c22f9","name":"SIA LIKESILK"},"previous":{"id":"8b54b1c2-b181-4871-9051-f3e09ed8de6b","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-14T09:26:48.713Z","supersededAt":"2026-09-16T14:42:35.178Z"},"next":{"id":"b2451a6d-6540-4eee-97f9-c79f09a8637a","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-17T11:33:00.608Z","supersededAt":"2026-09-18T11:33:11.123Z"},"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":[],"total":0,"byReason":{}},"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."],"outcome":"no_designated_holder_found","subject":{"number":"40203192814","entityId":"84f60c05-b230-434c-973c-e0f0152c22f9","countryId":"LV","entityName":"SIA LIKESILK"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"46bd3017efc9296ddb7bc683a20d686f5176afce142effdd6773c1727e9cb9fb","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":"8826482c6e3d3ac72d2b2edf419a0b09ba86883deafffb9cccd0a38fcf649b4c","signedOffOn":"2026-09-15","textsReadOn":"2026-09-13"},"statement":"No company listed under this regime holds any share of the company, anywhere in the chain the registers state. Natural persons hold one holding in the chain, including 100% of the company directly. The registers publish no identifier that confirms who they are, so they were compared with designated persons by name only, and a name written differently in a register and on a list is not found.","threshold":"50% or more","computedAt":"2026-09-16T14:42:35.178Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"No designated company appears anywhere in the chain the registers state. Natural persons in the chain were compared with designated persons by name only.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":100}}}