What OpenSanctions does and does not cover, including sanctioned crypto wallets, EU designations published ahead of the FSF database, and adverse media.
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What OpenSanctions does and does not cover, including sanctioned crypto wallets, EU designations published ahead of the FSF database, and adverse media.
OpenSanctions aggregates sanctions, politically exposed persons (PEPs), debarment lists used in government procurement, lists of known terrorists, and other entities of interest relevant to journalistic research and due diligence, drawn from hundreds of sources into a single, deduplicated dataset. What we include is governed by our data inclusion criteria, and every entity is tagged with risk topics that record why it is in the database.
This page answers common questions about what the data does and does not cover.
While sanctions have traditionally targeted persons and companies, an increasing number of authorities has now started to name cryptocurrency wallets as targets on their lists. These include the US OFAC, Israel's NBCTF, the Japanese MoF, and Britain's HMT/OFSI.
Using the OpenSanctions data model, you can screen individual wallet addresses and, when the source sanctions list names them, see the person or company that holds a wallet. Wallets are modelled with the CryptoWallet schema.
The primary source of EU sanctions data in OpenSanctions is the EU Financial Sanctions Files dataset, published by the European Commission (EC, DG FISMA). Uniquely among global sanctions authorities, the consolidated EU database is not produced by the same body that mints new sanctions designations. That task falls to the European Council, which publishes new sanctions in the Official Journal of the European Union (OJEU) in text form. The EC then republishes them in its official database, after some delay.
This delay — sometimes as long as 21 days — has caused a major headache for financial institutions and regulated entities, who risk facilitating sanctioned payments because their screening systems do not yet include the updated data.
To close that gap, we publish a dataset called EU Council Official Journal Sanctioned Entities, which includes new sanctions as soon as they appear in the OJEU. EU-regulated entities should consider using the EU Sanctions data collection to screen the EU FSF, Journal-only sanctions, and the national sanctions databases of EU member states such as France and the Czech Republic all at the same time.
To track OJEU sanctions updates, we run a continuous monitoring system that scans for changes to EU sanctions-related regulations. We begin from the legislation listed in the unofficial API of the EU Sanctions Map, assuming it is complete and up to date. From there, a combination of web scraping and SOAP-based querying (via the EUR-Lex web service) continuously monitors newly published legal documents.
The first step is to identify and extract the CELEX number of the original act when provided with a URL that may link to a consolidated version of the act (a document that combines the original legislation with all its subsequent amendments and corrections into a single, easy-to-read format). However, we are interested in retrieving the original document.
Each EU legal document has a unique CELEX number, used as the key identifier for that piece of legislation. It typically consists of a prefix indicating the document type (such as a regulation or directive), followed by a year and a sequential number:
02024D0254-20240202
Once we have the CELEX number, the system queries the EUR-Lex service, which houses EU legal documents. Tailored search queries then retrieve only the relevant legal texts, including regulations, directives, and any associated amendments.
When we identify a new document, the system checks whether it relates to an existing sanctions regime by comparing its CELEX number against those we've already seen. If the number is new, we send an alert to the #eu-journal channel in our public Slack and record the CELEX number to avoid duplicate alerts.
We trigger each alert only once per document, and a separate system notifies us of errors so that no new document is missed. Once alerted, we review the document and transcribe the compliance-relevant sanctions information into our database, typically within about three hours of publication.
"Adverse media" (also called "negative news") screening checks regulatory publications, news reports, social media, and press releases for unfavourable mentions of a customer or counterparty. Many regulators expect financial services companies to do it.
We include adverse information from a broad set of non-sanctions watchlists, such as regulatory lists and debarment databases. We do not include a comprehensive archive of news reports, social media postings, or press releases: Aggregating such content as a cleaned-up bulk data bundle would infringe the copyright of content publishers; it would also be a significant technical undertaking that calls for a different skill set than the detailed data cleansing OpenSanctions specializes in.
Your choice depends on several factors, so our guidance here is limited. Since OpenSanctions focuses on technical building blocks, here are two news aggregator APIs that take a similar approach: