{"id":"fdb28a23-c434-41d1-a9ff-b6a90482088d","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":"2026-09-16T14:39:18.373Z","confirmedAt":"2026-09-16T14:39:18.373Z","supersededAt":"2026-09-17T11:30:36.563Z","company":{"id":"19f933fe-7de4-4c12-9497-7252c2b18505","name":"SIA \"Anulatrans\""},"previous":{"id":"b4c696c6-fcb4-474b-97e1-af59a6d9b088","value":"No designated company found in the chain; the people in it are compared by name only","observedAt":"2026-09-14T09:25:46.759Z","supersededAt":"2026-09-16T14:39:18.373Z"},"next":{"id":"98f399e2-c6dc-41fc-a029-484dd0363661","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"},"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.","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":"fd05f7bcd56d3652f24269452a611796003bfd813b0943af31b0a57dff1f11a8","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 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":"50% or more","computedAt":"2026-09-16T14:39:18.373Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","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}}}