Navigating sanctions data to make the most effective use of the insights can be challenging. Here are some frequently asked questions that will help you, your organisation, your buyers and suppliers understand the different flags and what actions to take.
What are sanctions?
Sanctions are restrictive measures that can be put in place to fulfil a range of purposes. In the UK, these include complying with UN and other international obligations, supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism.
The UK implements a range of sanctions regimes through regulations made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Sanctions Act provides the main legal basis for the UK to impose, update and lift sanctions.
There are four main types of sanctions that can be imposed under SAMLA 2018:
Financial sanctions – to have an adverse financial impact on particular individuals or corporate entities;
Immigration sanctions – preventing “excluded persons” for the purposes of the Immigration Act 1971, entering or remaining in the UK;
Trade sanctions – disrupting various trade activities involving particular individuals, prescribed countries and/or specified ships, including in connection with goods, technology, land, military activities, and/or services (generally, or of a prescribed description);
Aircraft and shipping sanctions – imposing prohibitions or requirements or authorising directions with respect to aircraft connected with particular individuals and/or prescribed countries & measures designed to do the same with respect to ships that are connected with particular individuals and/or prescribed countries, and/or that are specified ships.
Who needs to comply with financial sanctions?
Taken from the OFSI FAQ general guidance:
UK financial sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world. This means that:
• All individuals and legal entities who are within or undertake activities within the UK’s territory must comply with UK financial sanctions that are in force.
• All UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force irrespective of where their activities take place.
So that's all of us then..
What happens if we find we are in breach of sanctions?
You can find full guidance on what to do if you suspect a breach of financial sanctions in the aptly named OFSI faq. However in summary the sooner you let OFSI know the better. "Regulations require individuals, entities and bodies to supply OFSI as soon as practicable with any information that would ‘facilitate compliance’ with the regulations. Any information provided will only be used for the purposes for which it was provided or received. This requirement applies to natural and legal persons, entities and bodies in the UK or under UK jurisdiction."
Don't our banks take care of all this? Do we have to worry about it?
We asked this question to trade.gov.uk who recommended that businesses check for themselves. Banks will also be doing their own checks of course, but will not be able to see into your supply chains or your other dotted line connections with entities. Consequently it makes sense to ask your suppliers what they are doing in order to prevent potential breaches as part of your own due diligence, if you are not doing so already.
What do the matches mean on my dashboard?
You can browse any matches we have found against your suppliers on your supplier dashboard. If we have found a positive match the dashboard will explain how we came to that conclusion.
This will be presented as a label with a percentage e.g. Director 96% with the percent representing the level of accuracy. This accuracy percentage accounts for typos and incomplete data in the sanction information so we try to display this as transparently as possible.
The labels are defined as such:
Entity - We found matches against the organisation's name and possibly also their registered address.
Director - We found matches against a director of the organisation comprising of their full name, nationality and date of birth.
Which sanctions data sets does TISCreport offer?
The sanctions dataset list below may vary a bit but here is a broad overview of datasets that can be included in your subscription on request:
|Asian Development Bank Sanctions
|The ADB's published sanctions list. It contains the names of entities who violated the sanctions while ineligible; entities who committed second and subsequent violations; debarred entities who are uncontactable; and cross debarred entities.
|Asian Development Bank
|United Arab Emirates Local Terrorist List
|The UAE's asset freeze list of individuals and legal entities that are
suspected of, attempt to, or commit terrorist acts.
|Executive Office for Control & Non-proliferation
|United Arab Emirates
|African Development Bank Debarred Entities
|Individuals and firms that have been sanctioned by AfDB, for having
participated in coercive, collusive, corrupt fraudulent or obstructive practices under the Bank’s sanctions system.
|African Development Bank Group
|Public Registry of Persons and Entities linked to acts of Terrorism and their Financing
|Ministry of Justice and Human Rights
|Australian Sanctions Consolidated List
|The Consolidated List is a list of all persons and entities who are subject to targeted financial sanctions under Australian sanctions law.
|Department of Foreign Affairs and Trade (DFAT)
|Azerbaijan Domestic List
|Domestic list of natural and legal persons subject to sanctions
|Azerbaijan Financial Monitoring Service
|Belgian Financial Sanctions
|Belgium extends the European FSF sanctions list on the basis of a national terrorist list, issued by the National Security Council.
|Federal Public Service Finance
|Bulgarian Persons of Interest
|A list of persons and companies sanctioned for involvement with terrorism financing released by the government in Bulgaria.
|Canadian Special Economic Measures Act Sanctions
|Sanctions imposed by Canada on specific countries, organizations, or individuals under the Special Economic Measures Act (SEMA) and JVCFOA.
|Global Affairs Canada
|Freezing Assets of Corrupt Foreign Officials Act
|The Canadian governments maintains a small, Magnitsky-style list of government officials that it alleges to be involved in corruption.
|Government of Canada
|Canadian Listed Terrorist Entities
|The Canadian governments own list of people and organizations associated with terrorism.
|Public Safety Canada
|Swiss SECO Sanctions/Embargoes
|Switzerland manages a sanctions lists with a high degree of detail on the individuals that are subject to it's embargoes.
|State Secretariat for Economic Affairs (SECO)
|EBRD Ineligible entities
|The EBRD published integrity sanctions. The entities and individuals listed are ineligible to become a Bank Counterparty for the periods indicated.
|European Bank for Reconstruction and Development
|Members of the European Commitee of the Regions
|The European Committee of the Regions (CoR) represents local and regional authorities across the European Union and advises on new laws that have an impact on regions and cities.
|European Committee of the Regions
|Europe's most wanted fugitives
|Wanted fugitivies listed on a Europol-operated web site.
|European Network of Fugitive Active Search Teams
|EU Financial Sanctions Files (FSF)
|As part of the Common Foreign Security Policy the European Union publishes a sanctions list that is implemented by all member states.
|European External Action Service
|Members of the European Parliament
|A set of all the members of the European Union's parliament, which are elected per member state.
|EU Sanctions Map
|The EU Sanctions Map is a visualisation of EU sanctions policy. It includes a broader set of policies and entities than the…
|Estonian Presidency of the Council of the EU
|EU Consolidated Travel Bans
|Consolidated information about individuals who have been banned from traveling to the European Union, released as part of the EU Sanctions Map.
|Estonian Presidency of the Council of the EU
|All members of national parliament in the world, collected from hundreds of government web sites and consolidated via Wikidata.
|MySociety (UK Citizens Online Democracy)
|French Freezing of Assets
|The register lists all persons, entities and vessels subject to asset freezing measures in force on French territory,…
|Ministry of Economy, Finance, and Recovery
|UK Companies House Disqualified Directors
|Individuals which have been disqualified from holding the post of a company director in the United Kingdom following…
|The Insolvency Service
|UK OFSI Consolidated List of Targets
|The United Kingom's consolidated international sanctions list.
|Office of Financial Sanctions Implementation
|NCA Most Wanted
|Most wanted list of criminals and fugitives in Britain, maintained by the United Kingdom's National Crime Agency (NCA).
|National Crime Agency (NCA)
|Inter-American Development Bank Sanctions
|The firms and individuals listed have been sanctioned for having engaged in fraudulent, corrupt, collusive, coercive or obstructive practices, in violation of the IDB Group’s Sanctions Procedures and anti-corruption policies.
|Inter-American Development Bank
|Israel Terrorists Organizations and Unauthorized Associations lists
|Terrorist organizations and individuals as designated by the Israeli government.
|National Bureau for Counter Terror Financing
|Indian Ministry of Home Affairs Banned Organizations
|List of banned organizations under the Unlawful Activities (Prevention) Act.
|Ministry of Home Affairs
|INTERPOL Red Notices
|International arrest warrants published by INTERPOL with a view to extradition of the wanted individuals.
|INTERPOL Yellow Notices
|Yellow notices are issued to help locate missing persons, often minors, or to help identify persons who are unable to identify themselves.
|Japan Economic sanctions and list of eligible people
|Sanctions imposed by Japan under its Foreign Exchange and Foreign Trade Law.
|Ministry of Finance
|Kyrgyz National List
|A simple list of sanctioned individuals and entities published by the Kyrgyz' State Financial Intelligence Service.
|ФИНАНСОВОЙ РАЗВЕДКИ ПРИ ПРАВИТЕЛЬСТВЕ КЫРГЫЗСКОЙ РЕСПУБЛИКИ (ГСФР)
|Kazakh Terror Financing list
|A simple list of sanctioned individuals and entities published by the Financial Monitoring Agency of Kazakhstan.
|Қазақстан Республикасының Қаржылық мониторинг агенттігі
|Lithuanian FIU International Sanctions
|A list of entities whose property is legally owned or controlled by a sanctioned entity.
|Finansinių Nusikaltimų Tyrimo Tarnyba (FIU)
|Moldovan ban list of economic operators
|List of economic operators banned from participating public procurement in Moldova
|Ministry of Finance of the Republic of Moldova
|RISE Moldova People of interest
|People of Interest is an interactive database developed and managed by RISE Moldova. It is a work in progress journalistic project.
|Netherlands Police Nationale Opsporingslijst (Wanted)
|The most wanted persons are suspected of serious crimes and are ranked high on the police's hit list.
|Korps Nationale Politie
|Dutch National Sanctionlist Terrorism
|The Dutch government's sanctions list of people suspected of involvement in terroristic activities.
|Ministry of Foreign Affairs
|New Zealand Russia Sanctions
|The New Zealand government's list of people and companies sanctioned in relation to the Russian attack on Ukraine.
|Ministry of Foreign Affairs and Trade
|Polish list of persons and entities subject to sanctions
|Decisions by the Polish Interior Ministry regarding entities linked to the aggression in Ukraine.
|Ministerstwo Spraw Wewnętrznych i Administracji
|Qatar Unified Record of Persons and Entities on Sanction List
|This dataset contains both UN-mandated and the national sanctions designations for Qatar (Targeted Financial Sanctions).
|National Counter Terrorism Committee (NCTC)
|ransomwhe.re ransomware addresses
|Cryptocurrency addresses linked to payments for ransomware attacks
|ransomwhe.re / Jack Cable
|ACF List of bribetakers and warmongers
|A list of key Russian decision-makers from government and business composed by ACF/FBK, the…
|Anti-Corruption Foundation (ACF)
|Forbes 2021 List of Russian Billionaires
|Based on an annual assessment of wealth and assets compiled and published by Forbes magazine in 2021.
|Rosfinmonitoring List of terrorists and extremists
|List of organizations and individuals involved in extremist or terrorist activities.
|Rosfinmonitoring WMD-related entities
|List of organizations and individuals in relation to which there is information about their involvement in the proliferation of weapons of mass destruction
|FBK Recommended List of Individuals for Sanctioning (Navalny 35)
|A list of suggested sanctions targets published by Navalny's FBK in a letter to Dominic Raab.
|Anti-Corruption Foundation (FBK)
|National Settlement Depository (NSD Russia) ISIN Assignment
|ISIN security identifiers assigned in Russia and subject to a US investment ban.
|National Settlement Depository
|RuPEP Public Database of PEPs in Russia and Belarus
|RuPEP is a detailed database of politically exposed persons in Russia and Belarus maintained by qualified researchers
|Singapore Targeted Financial Sanctions
|Terrorists and terrorist entities designated by the Singapore government on top of the UN security council set of sanctions.
|Monetary Authority of Singapore
|Ukraine NABC Sanctions Tracker
|A list of suggested Russia-related sanctions targets composed by the Ukrainian anti-corruption agency.
|National Agency on Corruption Prevention
|Ukraine National Security Sanctions
|List of individuals and legal entities subject to restrictive measures.
|National Security and Defense Council
|Ukraine SFMS Blacklist
|Ukraine's financial intelligence unit publishes this list of sanctioned individuals.
|Державна служба фінансового моніторингу України (Держфінмоніторинг)
|UN Security Council Consolidated Sanctions
|The Security Council's set of sanctions serve as the foundation for most national sanctions lists.
|United Nations Security Council (UN SC)
|US BIS Denied Persons List
|The Bureau of Industry and Security publishes this list of entities which are relevant with regards to export controls.
|Bureau of Industry and Security (BIS)
|CIA World Leaders
|An index of most national-level cabinet members in world governments that is publicly maintained by the CIA.
|Central Intelligence Agency (CIA)
|US State Department Cuba Sanctions
|Several lists of Cuban companies and hotels that are blocked by the US State Department separately from the sanctions lists maintained by the Treasury.
|US State Department
|FBI Most Wanted
|The FBI Ten Most Wanted Fugitives is a most wanted list maintained by the United States's Federal Bureau of Investigation (FBI).
|Federal Bureau of Investigation (FBI)
|OCC Enforcement Actions
|The US banking regulator OCC publishes a list of companies and individuals against which punitive measures have been applied.
|Office of the Comptroller of the Currency
|US OFAC Consolidated (non-SDN) List
|OFAC is providing all of its non-SDN sanctions lists in a consolidated set of data called "the Consolidated Sanctions List".
|Office of Foreign Assets Control (OFAC)
|US OFAC Specially Designated Nationals (SDN) List
|The primary United States' sanctions list, specially designated nationals (SDN) part.
|Office of Foreign Assets Control (OFAC)
|US SAM Procurement Exclusions
|A database of suppliers who have been excluded from participating in US federal procurement.
|General Services Administration (GSA)
|US Trade Consolidated Screening List (CSL)
|The Consolidated Screening List (CSL) is a list of parties for which the United States Government maintains restrictions on certain exports, reexports, or transfers of items.
|Department of the Commerce - International Trade Administration
|Wikidata Entities of Interest
|Persons of interest profiles from Wikidata, the structured data version of Wikipedia.
|Russian Oligarch Database
|A list of oiligarchs from CIS countries, most notably the Russian Federation.
|Wikidata Politically Exposed Persons
|Profiles of politically exposed persons from Wikidata, the structured data version of Wikipedia.
|WorldBank Debarred Providers
|The firms and individuals listed in this dataset are debarred and thus ineligible to participate in World Bank-financed contracts for the periods indicated.
|South African Targeted Financial Sanctions
|The South African FIC sanctions list, largely based on UN Security Council sanctions.
|Financial Intelligence Centre (FIC)