{"id":"fd136c04-cd1e-4096-ada6-710081b2b9c8","test":"UK ownership and control","value":"No designated company found in the chain; the people in it are compared by name only","current":true,"observedAt":"2026-09-18T11:30:41.818Z","confirmedAt":"2026-10-25T11:30:41.212Z","supersededAt":null,"company":{"id":"19f933fe-7de4-4c12-9497-7252c2b18505","name":"SIA \"Anulatrans\""},"previous":{"id":"f9ce93d0-7e2f-4352-bb35-695f91d3c5c8","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-17T11:30:36.563Z","supersededAt":"2026-09-18T11:30:41.818Z"},"next":null,"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":[],"total":0,"byReason":{}},"effect":null,"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":"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":["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.","1 party in this chain is listed under a regime whose ownership rule has not been verified here, and was not counted: SIA \"Anulatrans\" (Latvia FID frozen assets register)."],"outcome":"no_designated_holder_found","subject":{"number":"40003431947","entityId":"19f933fe-7de4-4c12-9497-7252c2b18505","countryId":"LV","entityName":"SIA \"Anulatrans\""},"holdings":{"total":3,"heldByCompanies":0,"notPublishedAsCompanies":3},"identity":"cd3ee710f996aea55bda5f933eaf4d87a9c50d95146d99aa1fd73bf8f20eda02","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":"f3d899fc1d224a36dbf3880253f4312f1c7fcc70e367d56af13ffb8b20bd8c88","signedOffOn":"2026-09-17","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 3 holdings 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":"more than 50%","computedAt":"2026-09-18T11:30:41.818Z","aggregation":"not_aggregated_without_joint_arrangement","chainComplete":true,"jointHoldings":"each_joint_holder_holds_all","listedParties":[{"hops":0,"company":{"name":"SIA \"Anulatrans\"","number":"40003431947","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":null,"regime":"Latvia","status":"not_verified","program":"Līdzekļu iesaldēšana — Kapitāldaļas","entityId":"19f933fe-7de4-4c12-9497-7252c2b18505","entityName":"SIA \"Anulatrans\"","sourceName":"Latvia FID frozen assets register","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":0,"includingJoint":0},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":0,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":3,"masked":0,"directShareOfSubject":100}}}