Ownership test · OFAC 50 percent rule
Designated itself, so blocked
About ELFARO OU, assessed under EE number 14329778.
First said on 16 Sept 2026, and replaced on 17 Sept 2026. A daily run that reaches the same verdict on the same holdings, listings and breaks confirms it. When anything it rests on changes, a new verdict begins at a new address.
- Before it, from 14 Sept 2026 to 16 Sept 2026: “Designated itself, so blocked”
- After it, from 17 Sept 2026 to 18 Sept 2026: “Designated itself, so blocked”
The words can stay the same across two verdicts: a verdict is replaced when a holding, a listing, a break or the signed rule table changes, even where its words do not.
What it says
The company is itself listed under this regime, and blocked as a listed party rather than through its owners.
- Designated share
- Listed itself
- Threshold
- 50% or more
- Effect
- Blocked
- Chain
- Breaks at 1 point
- Nearest designated party
- The company is itself designated.Found across every list on file, not only those this rule counts.
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.
The chain
Holdings the result passes through
None: the company is listed itself, so the verdict does not pass through any holding.
Holdings read
The registers read state no holdings for the chain.
Listed parties in the chain
ELFARO OU (EE 14329778) the company itself
- CountedOFAC SDN
Asset freeze under OFAC, RUSSIA-EO14024
Listed as ELFARO OU
Counted under this rule.
Where the chain breaks
The chain could not be followed past 1 point, and past a break nothing is known. This verdict does not rest on the chain, because the company is listed itself; the breaks are kept with it all the same.
- No holders published: 1
No holders published at the company itself
Estonia e-Business Register (shareholders) 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.
What it rested on
Lists this rule reads
OFAC SDN
Read on 13 Sept 2026; dated 10 Sept 2026 by the publisher.
Shareholder registers
Estonia e-Business Register (shareholders)
File read on 14 Sept 2026; last modified 13 Sept 2026, by the publisher's server. None of its holdings were used.
The rule
- Test
- OFAC 50 percent rule
- Threshold
- 50% or more
- Several designated owners
- Added together: the shares of different designated parties count as one.
- A jointly held share
- The texts read do not settle it, so a result that rests on one goes to a reviewer.
- Control
- Not assessed. A shareholder register shows shares, not board seats or agreements.
- Signed off
- On 15 Sept 2026, from texts read on 13 Sept 2026.
8826482c6e3d3ac72d2b2edf419a0b09ba86883deafffb9cccd0a38fcf649b4c
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.
Texts the rule rests on
- OFAC, Frequently Asked Questions: Entities Owned by Blocked Persons (50% Rule)
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)
This record
- Address
- This page's address does not change, and the verdict at it is never rewritten. The same record as JSON.
- Computed
- 16 Sept 2026
- Identity
d02b71ca90e7a3d20a8c645b2c569ef516b1bf9a0ff3cdc6c7e05e0a19643457A hash of what the verdict rests on. Each run compares it to decide whether the verdict still stands.