Frequently asked questions

A big part of the challenge of sanctions compliance is to track and identify corporate ownership structures associated with sanctioned entities (see, for example, the OFAC 50 Percent rule and its European regulatory counterpart).

We see this as an exciting challenge, which we are beginning to address by including relevant records on links between companies, vessels and individuals from non-risk datasets, such as company and other reference databases. For example, we include sanctions-linked companies from the Russian cimpany database, ICIJ OffshoreLeaks, GLEIF, Open Ownership and several other national company databases. We also link to, but don't include detailed data from OpenCorporates.com in a way that enables the easy integration of data from both sources in downstream data pipelines.

However, the beneficial ownership information included as a result of these efforts does not result in an exhaustive global database of companies affected by the US 50 Percent rule (and entities owned or controlled by Listed Entities under the EU's definition). The most notable gap in the current coverage is the subsidiaries of Chinese entities listed on various government watchlists.

Finally, we want to emphasize that gathering intelligence on the opaque networks of entities associated with designated persons and companies is a task for which governments (equipped with investigative bodies, intelligence agencies and access to beneficial ownership registers, as well as suspicious activity reports filed by financial institutions) are far better equipped than the private sector and civil society. The 50 Percent rule, while well-intended, must also be considered a failure of government to properly perform its own role in the design and implementation of effective sanctions regimes.