Frequently asked questions

#168: What are sanctions programs?

Category: Data structure · Last updated: · Permalink

Sanctions programs are the specific government policies that form the legal basis for designating individuals, companies, vessels, or other entities as sanctioned. Each program usually defines a scope and a set of measures that the issuing government will impose on the sanctions target. Governments often publish designations from multiple programs as one list, which we represent as a data source.

For example, the US Trade Consolidated Screening List dataset includes dozens of programs, including the BIS Denied Persons List, BIS Military End-Users List, etc.

We sometimes use the term program a bit more broadly, to identify sub-lists inside of a single data source. For example, the ICIJ Offshore Leaks database includes the Panama Papers, Paradise Papers, and Pandora Papers as programs.

Program descriptions serve as in-depth metadata, and individual entities in the database are increasingly linked to the programs they are designated/targeted under using the programId property. Together with the programs metadata JSON (see below), this can be used to include program descriptions in applications consuming the data, showing the exact legal or policy basis for a sanction.

Please note: the same person might be listed under multiple programs if they are sanctioned for different reasons by different authorities or countries.

The sanctions program description includes:

  • Program key - identifier, e.g. [EU-RUS] EU Sanctions against Russia
  • Issuing authority (e.g. OFAC, UN Security Council)
  • Country of issuer responsible for the program
  • Targeted territories that this program is linked to (note the use of country code ip for "Cyberspace").
  • Related dataset - some programs are covered by multiple datasets, but one is chosen here as a primary source.

You can view the full list of sanctions programs here. You can also fetch a JSON file containing details on the issuing authority, country, and related datasets. The file is updated every multiple times per day:

https://data.opensanctions.org/meta/programs.json

For further reading on sanctions program mapping, check out our blog post on this topic.

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