Open AML Data Sources

Open AML data sources are public, official or clearly attributable sources that can support AML/KYC/KYB review. They do not replace regulated database subscriptions, local legal obligations or reviewer judgement. Their value is strongest when they are used as evidence anchors: source, date, identifier, limitation and relevance.

1. Purpose #

This page maps the open-source data layer of the AML Bible. It focuses on sources that a person can inspect, cite, verify and explain.

2. Source categories #

Category Examples Main AML use Evidence strength
Official sanctions lists UN, OFAC, EU, UK TFS and sanctions screening baseline High, if current and in-scope
Corporate registries Companies House, national registries KYB, existence, officers, filings, control signals High for registry facts, limited for risk conclusions
Legal entity identifiers GLEIF LEI Entity identity, cross-system matching High for LEI record, limited if entity lacks LEI
Beneficial ownership standards Open Ownership BODS Structuring BO data consistently Methodology source, not a live risk list
Investigative datasets ICIJ Offshore Leaks, OCCRP Aleph Leads on offshore structures and public-interest investigations Lead source; requires corroboration
Aggregators OpenSanctions, OpenCorporates Cross-source discovery and entity enrichment Useful but should be traced back to original sources
Debarment lists World Bank, ADB, EBRD Procurement integrity and corruption-risk screening High for listed ineligibility context
FATF materials Recommendations, methodology, NRA, typologies Country risk, typologies, RBA logic Core standard / methodology source

3. Evidence rule #

For every open source, record:

  • source name;
  • official URL;
  • search term or identifier used;
  • date and time checked;
  • result summary;
  • limitation of the source;
  • whether the finding is a fact, a lead, a risk indicator or a decision input.

4. What open sources can do well #

Open AML sources can help confirm entity existence, legal names, officers, LEI records, sanctions designations, published debarments, FATF country status, known typology indicators and public investigative leads.

They are especially useful for learning, triage, transparency and building evidence packs that show how a conclusion was reached.

5. What open sources cannot do #

Open sources usually cannot provide full commercial PEP coverage, full adverse media coverage, complete UBO coverage, domestic regulator-specific obligations, local filing instructions, internal risk appetite, private subscription data or final compliance decisions.

6. Source priority #

Prefer primary and official sources when they exist. Use aggregators for discovery, enrichment and search convenience, then trace important findings back to the original source where possible.

7. Boundary #

Boundary: data-source map only. Filing instructions, legal conclusions and final case decisions require the current local rule and accountable review.

8. Beginner rule: sources are not answers #

A source can provide a fact, a lead, a warning signal or a context layer. It does not automatically provide the final AML decision.

Use this mental model:

official source → stronger factual anchor
aggregator → discovery and enrichment
investigative/leak source → lead requiring context
media source → allegation or public-risk signal
missing result → not proof that no risk exists

For beginners, the most important habit is to write down what the source actually proves and what it does not prove.

Example:

Source result Safe interpretation
Company found in official registry The company appears in that registry under the checked identifier.
No sanctions result found No match was found in the checked source at that time; it is not proof that sanctions risk is impossible.
Name appears in leak database There is an investigative lead; identity and relevance require review.
Open web allegation found The allegation should be assessed for source quality, identity match, recency and relevance.

See Also#

References#

  • Official source hierarchy and evidence-weight rules listed in the Source Register.
  • Underlying official registers, sanctions lists, LEI/GLEIF, court/government and registry materials where applicable.
  • Editorial & Source Policy for use of aggregators and investigative sources.