Ownership test · Canadian deemed ownership
No designated holder found where the chain could be followed; it breaks at 4 points
About K Dystrybucja Sp. z o.o., assessed under PL number 0000965303.
First said on 18 Sept 2026, last confirmed on 24 Oct 2026. It is the current verdict under this rule. 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.
What it says
No party listed under this regime was found on the part of the chain that could be followed. The chain breaks at 4 points, and past a break nothing is known. Natural persons hold 4 holdings in the chain, including 100% of the company directly. The register publishes their names masked, so none of them was compared with any designated person.
- Designated share
- None found
- Threshold
- 50% or more
- Chain
- Breaks at 4 points
- Nearest designated party
- The company is itself designated.Found across every list on file, not only those this rule counts.
Notes
- 4 natural-person holdings are published with a masked name and were compared with nobody.
- 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: no holding carries a designated party's share down to the company.
Holdings read
4 holdings were read in the chain, none of them held by a company. Natural persons hold 4 of them, including 100% of the company directly. 4 are published with the name masked. A verdict never keeps a person's name: a person appears in it as a holding of a stated share.
Listed parties in the chain
K Dystrybucja Sp. z o.o. (PL 0000965303) the company itself
- Not countedPoland MSWiA sanctions list
Asset freeze under Poland, wykluczenie z postępowania o udzielenie zamówienia publicznego lub konkursu
Listed on 26 Apr 2022 as K Dystrybucja Sp. z o.o.
Not counted: this regime's ownership rule has not been read here.
Where the chain breaks
The chain could not be followed past 4 points, and past a break nothing is known. An answer about the chain covers only the part before them.
- Person's name masked: 4
Person's name masked at the company itself, 25% of it
A person holding 25% is published with the name masked, so whether that person is designated cannot be asked at all.
Person's name masked at the company itself, 25% of it
A person holding 25% is published with the name masked, so whether that person is designated cannot be asked at all.
Person's name masked at the company itself, 25% of it
A person holding 25% is published with the name masked, so whether that person is designated cannot be asked at all.
Person's name masked at the company itself, 25% of it
A person holding 25% is published with the name masked, so whether that person is designated cannot be asked at all.
What it rested on
Lists this rule reads
Canada Consolidated Autonomous Sanctions List
Read on 17 Sept 2026.
Shareholder registers
Poland KRS (current extract, read on demand)
Asked when the verdict was computed. The holdings used were read on 18 Sept 2026.
The rule
- Test
- Canadian deemed ownership
- Threshold
- 50% or more
- Several designated owners
- The texts read do not say. Each party is taken alone, and a result reached only by adding them goes to a reviewer.
- 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 17 Sept 2026, from texts read on 13 Sept 2026.
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Caveats
- The company is not listed itself. The Act deems what a company controlled by a listed person owns to be owned by that person, so dealing in the company's property is dealing in the listed person's.
- The Act speaks of a person holding 50% or more. Neither the Act nor the guidance of Global Affairs Canada says whether the holdings of different listed persons are added together, so a result reached only by adding them goes to a reviewer.
- Global Affairs Canada's guidance, which it says is general information and not legal advice, reads control widely: considerable influence over a company's strategic decisions is enough, and in one of its scenarios so is a listed person on the board of a company's owner.
- The Act counts holdings held directly or indirectly, and deems what a controlled company owns, its own holdings included, to be the listed person's in full.
- 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: K Dystrybucja Sp. z o.o. (Poland MSWiA sanctions list).
Texts the rule rests on
- Special Economic Measures Act, S.C. 1992, c. 17, section 2.1 (added by S.C. 2023, c. 26, s. 253)
Subsection 2.1(1): property owned, or held or controlled directly or indirectly, by an entity a person controls is deemed to be owned by that person. Subsection 2.1(2): the person controls the entity if (a) it holds, directly or indirectly, 50% or more of the shares or ownership interests or of the voting rights, (b) it can change the composition or powers of the board, or (c) it can direct the entity's activities by any means
- Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), S.C. 2017, c. 21, section 2.01
The same deeming provision and criteria, for a foreign national listed under that Act
- Global Affairs Canada, Canadian sanctions: Frequently asked questions (modified 2026-08-14), and Canadian sanctions: Essential information (modified 2026-07-17)
"Can I deal with the subsidiaries of a designated company?": the three criteria, a majority-owned subsidiary, and a subsidiary over whose strategic decision-making the parent has considerable influence; Essential information, scenario 3 (a listed person on the board of the buyer's owner)
- The Canadian regulations in CANADA_REGULATIONS_APPLIED, as consolidated on Justice Laws
The dealings ban of each, which forbids dealing in property a listed person owns, holds or controls
This record
- Address
- This page's address does not change, and the verdict at it is never rewritten. The same record as JSON.
- Computed
- 18 Sept 2026
- Identity
ac103ee0f90f37dc8075dd6a415d35ba1a1cc09934695ceeed7c29cf27acad67A hash of what the verdict rests on. Each run compares it to decide whether the verdict still stands.