Not on the list, still blocked: ownership adds up

Normalization

• Creditor name (Cdtr/Nm): “Voronets Delta Shipping LLC” → “VORONETS DELTA SHIPPING” (Uppercase and strip the legal-form suffix (LLC); the remaining tokens are indexed individually so distinctive tokens can match on their own.)

Candidates

• le-voronets-dmitri: matched on Distinctive surname token VORONETS in an entity name — Token rarity index: VORONETS occurs in almost no other name in the screening universe, so a single-token overlap is enough to generate a candidate despite the person-versus-entity mismatch.
• le-voronets-sergei: matched on Distinctive surname token VORONETS in an entity name — Same rare-token mechanism; both listed individuals share the surname and both are pulled in for scoring.

Scores

• le-voronets-dmitri: total 0.80 vs threshold 0.80 (Distinctive token match 45%×90%; Overall name similarity 25%×62%; Country corroboration 20%×100%; Entity type consistency 10%×40%)
• le-voronets-sergei: total 0.79 vs threshold 0.80 (Distinctive token match 45%×90%; Overall name similarity 25%×58%; Country corroboration 20%×100%; Entity type consistency 10%×40%)

Disposition

Alert generated. The higher-scoring candidate lands exactly on the 0.80 threshold: a rare listed surname inside a counterparty company name in a matching jurisdiction is precisely the pattern that ownership rules exist to catch, so the case goes to investigation rather than auto-release.

Investigation

1. Is Voronets Delta Shipping LLC itself designated on any list the institution screens against? Evidence: A full search across all screened lists returns no entity entry for the company under its name, its trade name, or its fictional registration number. Finding: The company is not designated in its own name.
2. Who owns the company? Evidence: Fictional corporate registry extract in the case file: Dmitri Aleksandrovich Voronets holds 35 percent, Sergei Aleksandrovich Voronets holds 30 percent, and an unrelated investor holds the remaining 35 percent; Both Voronets individuals are designated under Fictional Programme ALPHA. Finding: Two listed persons together hold 65 percent of the company.
3. What does the ownership rule make of a 35 percent plus 30 percent split? Evidence: OFAC's guidance on entities owned by blocked persons: an entity owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons is itself blocked, even when it appears on no list; The same guidance aggregates the stakes of multiple blocked persons, and it speaks to ownership only — control without majority ownership does not automatically block, though the authority can separately designate on that basis. Finding: At 65 percent aggregate ownership, the company's property is treated as blocked by operation of the rule; no individual stake needed to reach 50 percent on its own.
4. Does this payment fall within the reach of that rule? Evidence: The payment is denominated in US dollars and routed through Meridian Bank, the institution's fictional New York correspondent; The institution's sanctions policy applies OFAC-style ownership analysis to all USD traffic. Finding: The US-dollar leg brings the payment within the scope the institution's policy assigns to the rule.

Final: True match — escalate. Keep the payment on hold and escalate to sanctions compliance with the registry extract and the 35 + 30 = 65 percent ownership calculation. The choice between blocking and rejecting, and any reporting obligation, sits with that team and depends on the programme and jurisdiction involved.