Sanctions Data Sources
Sanctions data sources are dynamic lists, notices and tools used to identify designated persons, entities, vessels, aircraft and other restricted subjects. Sanctions screening must be treated separately from ordinary adverse media because a true match may trigger immediate legal and operational consequences.
1. Core official sources #
| Source | What it provides | Use in AML/KYC/KYB | Limitation |
|---|---|---|---|
| UN Security Council Consolidated List | UN listed individuals and entities in downloadable formats | Global TFS baseline | National implementation may add local details |
| OFAC Sanctions List Search / OFAC lists | US SDN and non-SDN search, fuzzy matching and list data | US sanctions exposure and entity matching | Applicability depends on legal scope and policy overlay |
| EU Sanctions Map / EU consolidated data | EU sanctions regimes, measures and designated subjects | EU sanctions exposure | Must distinguish map guidance from source list data |
| UK Sanctions List | UK sanctions designations | UK sanctions exposure | Current UK source; older OFSI consolidated list is historical/reference-only from 28 January 2026 |
| OpenSanctions | Aggregated sanctions, PEP and risk datasets from many sources | Discovery, enrichment and cross-source matching | Aggregator, not a sanctions authority |
2. Matching logic #
A sanctions source hit should be classified carefully:
| Result | Meaning | Evidence action |
|---|---|---|
| No apparent match | No relevant result at the checked time | Record source and date |
| False positive | Name similar but identifiers do not support match | Record why ruled out |
| Possible match | Some overlap, not enough identifiers | Escalate for review and collect more non-sensitive identifiers |
| Likely match | Strong identifier overlap | Escalate immediately |
| True match | Confirmed designation or ownership/control link | Follow local sanctions procedure |
3. Data points to compare #
- full legal name;
- aliases and transliterations;
- date of birth or incorporation date;
- place of birth or registration jurisdiction;
- nationality or registration number;
- addresses;
- vessels, aircraft, IMO numbers or other identifiers;
- ownership/control links;
- source list and programme/regime.
4. Evidence value #
Official list entries have high evidence value for the fact of designation. However, the legal consequence depends on the jurisdiction, the institution's obligations, the customer relationship, ownership/control analysis and local policy.
Aggregators have strong discovery value but important matches should be traced to the original list before relying on them.
5. Source basis #
- SRC-UN-001: UN Security Council Consolidated List.
- SRC-OFAC-001: OFAC sanctions list search and list data.
- SRC-EU-001: EU Sanctions Map and consolidated EU financial sanctions data.
- SRC-UK-001: UK Sanctions List.
- SRC-OS-001: OpenSanctions.
- SRC-FATF-001: FATF Recommendations on TFS and sanctions-related controls.
6. Boundary #
Boundary: source types and evidence handling only. Legal sanctions obligations require the applicable authority, programme, list version and local rule.
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.