Sanctions Program Mapping: Better Transparency and Navigation

Answering those questions often requires digging through legal texts or parsing cryptic designations across multiple lists.

That's why we’ve been working to make this easier: You can now see connections between sanctioned entities in the database to the specific sanctions policy programs under which they’ve been designated based on identifiers found in the original source data.

This applies across datasets where the issuing authority assigns a program name or legal reference to a designation (for example, the EU consolidated sanctions list, OFAC’s SDN list, or the UK sanctions regime). This update is not just a technical upgrade. It fundamentally improves how users can explore, understand, and analyze sanctions data on OpenSanctions.

Why Sanctions Programs Matter

Sanctions programs define the legal scope, criteria, and rationale behind each designation. While consolidated sanctions lists often contain thousands of entries, each designation typically originates from a specific program, such as:

• EU Sanctions against Russia
• UK arms embargo on mainland China and Hong Kong
• US Foreign Sanctions Evaders (FSE) List

These programs can correspond to executive orders, laws, or international regimes, and they determine:

• The scope of restrictions: e.g., asset freezes, travel bans, or trade prohibitions
• Criteria for inclusion: e.g., human rights violations, proliferation, terrorism
• Enforcement and reporting obligations: by governments, financial institutions, and companies

Surfacing this information at the entity level provides essential legal and analytical context for each listing.

What’s Changed: A More Connected Sanctions Database

We’ve introduced several key improvements to how programs are handled in OpenSanctions:

The program is now clearly displayed on the entity’s listing page.

programId Field for Entities

Entity records for sanctioned entities now include a programId property, whenever a mapping is available. This field identifies the specific program or legal instrument responsible for the listing.

This change affects all datasets where programs are explicitly named. For example, OFAC, the UK government, and the EU all indicate which program a designation belongs to. Previously, this information was often buried in source data. Now, it’s structured and queryable.

You can see an example in our data explorer, where the programId is visible under advanced metadata.

Clickable Program Links from Entity Pages

Entity pages now allow you to click directly through to the associated sanctions program. For instance, an individual listed under the "Russian sanctions regime" will now have that program linked, allowing you to explore all related designations under it with a single click.

Standardized program identifiers power this internal linking. We match the source program IDs (from OFAC, EU, UK, etc.) with our internal ones, creating a fully connected and navigable infrastructure.

A direct link to the program allows you to explore its scope and related designations.

Cleaner Program Pages with Descriptions

Program pages now include improved metadata and human-readable descriptions. This means users can see not just a list of entities but also the scope and background of the sanctioning effort.

This makes it easier to understand what a regime covers and how individual listings relate to larger geopolitical or legal developments.

Examples and Oddities

The Turkish businessman with his own US Sanctions program

“I am the list.” — Judge Dredd: Sanctions Bureau

One standout example of our new program mapping is Evren Kayakiran, a Turkish businessman listed by the US Department of the Treasury under the Foreign Sanctions Evaders (FSE) List. What's remarkable is that Ayan is the only individual currently listed under this specific FSE designation program. In effect, he has a US sanctions program all to himself.

This peculiar example demonstrates the usefulness of program-level mapping. Previously, this level of granularity was not visible. The FSE tag might appear, but users couldn’t explore the scope of the program or see how many entities were listed under it. With our new program mapping, you can click the program link and see exactly how many entities it covers (just one), view background context, and understand the legal framework behind it.

For reference, you can view his OFAC entry in the FSE list PDF and the full program on OFAC’s other sanctions lists page.

UNSC 1373: One resolution, many national lists

Another unusual case involves the UN Security Council Resolution 1373 (UNSC 1373), a counter-terrorism framework adopted in the wake of the September 11 attacks. Unlike traditional UN sanctions regimes (like those under UNSC 1267 for ISIL/Al-Qaida), Resolution 1373 does not establish a centralized UN-managed sanctions list. Instead, it requires each UN member state to create its own legal and procedural framework for identifying and sanctioning individuals and entities involved in terrorism.

This decentralized structure presents a unique challenge for sanctions data, as there is no single, authoritative list of UNSCR 1373 designations; instead, there are country-specific implementations. For example:

• Canada maintains a list of designated terrorists under its implementation of UNSCR 1373
• Australia’s DFAT counter-terrorism sanctions regime also maps directly to 1373, even though its designations are only listed domestically
• Other countries like the US, UK, and EU implement 1373 through legal instruments such as Executive Orders, Terrorism Acts, or Council Regulations In OpenSanctions, we've chosen to assign the ID UN-SC1373 to help users trace these regimes back to their shared legal origin, while mapping each dataset (e.g. au_dfat or ca_listed_terrorists) to its national source. In the case of Australia, the designations are specific to DFAT, but grounded in their interpretation of the UNSCR 1373 obligations. This is a good example of how program mapping helps users navigate decentralized international obligations that produce localized lists under a common legal framework.

Bringing Structure to the Data

With this update, we aim to provide clarity by mapping sanctioned entities to their originating programs, offering a deeper and more precise view of why an entity is listed, under what authority, and how different sanctions regimes interconnect.

We’ll continue to expand this feature as more programs and legal mappings emerge. As always, if you spot something unusual (or delightfully weird, like another program with only one member), we’d love to hear from you.

👉 Explore some of the programs now, or reach out to us if you have ideas, feedback, or questions.