Terms of Service (Previous version)

The goal of the OpenSanctions website, its API, and associated websites (“OpenSanctions”) is to improve access to and quality and understanding of data about individuals and companies under sanctions, as well as politically exposed persons, under a license that encourages reuse. In short, we want you to use our data, for a public purpose, for journalism, for academic research, for other great open data websites and services, and also commercially.

Effective date: 18. October 2022; superseded at: 1. March 2024.

We are strong champions of open data, and of business models that support and encourage open data. OpenSanctions is published by OpenSanctions Datenbanken GmbH, a company registered in Berlin, Germany, AG Charlottenburg HRB 251172 B (“we”, “us”, “our”). These are the terms on which we make the OpenSanctions website available to you. We have tried to put them in plain language as far as possible, but unfortunately a certain amount of legalese is necessary.

We offer access to our website, database search, bulk data download and API, and also paid-for access to our API. If you have agreed to a paid-for contract for use of bulk data or our API, these terms and conditions supplement that contract and, in cases of conflict, the paid-for contract will take precedence.

Disclaimers and Limitation of Liability

The data on companies that is available through OpenSanctions (“persons of interest data”) is drawn from many different government sources. In some cases the source data have errors which we have not yet detected and in other cases the data has been provided in very complex and impenetrable formats, which may have given rise to errors in the way it is presented on OpenSanctions.

Therefore we cannot make any promises as to the quality of company data. You use the company data entirely at your own risk.

For this reason, and because OpenSanctions is made available without charge, we limit our liability as follows.

OpenSanctions is provided “AS IS” and on an “IS AVAILABLE” basis without any representations or any kind of warranty made (whether express or implied by law) to the extent permitted by law, including the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.

Under no circumstances will we be liable for any of the following losses or damage (whether such losses were foreseen, foreseeable, known or otherwise): (a) loss of data; (b) loss of revenue or anticipated profits; (c) loss of business; (d) loss of opportunity; (e) loss of goodwill or injury to reputation; (f) losses suffered by third parties; or (g) any indirect, consequential, special or exemplary damages arising from the use of OpenSanctions regardless of the form of action.

We do not warrant that functions contained in OpenSanctions content will be uninterrupted or error free, that defects will be corrected, or that OpenSanctions or the servers that make it available are free of viruses or bugs.

Your use of OpenSanctions

Our goal is to make information on entities which are subject to sanctions, politically exposed, or of other special interest widely available and available for reuse, and because of that we not only do not charge for use of the site, we also provide bulk data and an API to allow easy access to the underlying data under an open license. However, we do need to ensure that we can continue to provide the service for the benefit of all, and so need to place certain restrictions on use of the site. For example, “scraping” imposes an unreasonable demand on our servers, and is unnecessary because of the bulk data access we provide. Therefore you must not scrape the OpenSanctions website to extract data, and if you wish to make use of the published data in bulk, then you should make use of the OpenSanctions bulk data through a commercial license or through our API (see “Use of the API” below), or contact us.

We do not use the robots exclusion protocol to prevent the scraping of our site, because we wish other forms of web crawling – such as by search engines – to be possible. The absence of a robots.txt file does not mean we permit arbitrary scraping.

For this reason, and others (e.g. abuse, spam, etc), we may have to forbid use of OpenSanctions in some circumstances. You may not use OpenSanctions if we have previously forbidden you to do so, nor may you do so on behalf of someone else we have forbidden from using OpenSanctions. Access to OpenSanctions in these circumstances may constitute a criminal offense under § 303b (Computersabotage) of the German penal code. We will consider prosecuting individuals or companies who access our site when forbidden to do so.

Use of the OpenSanctions API

The OpenSanctions API may be used either with an API key. Use of the OpenSanctions API with an API key allows a greater number of requests in a given period (e.g. hour, day). Use of the OpenSanctions API without an API key is designed to allow the data to be used in widgets and other client-side applications, or for the development stage of applications that are not yet ready to launch, and is intended for light usage only.

API keys are available in two ways: on a donated basis to anyone legitimately working on a project that will contribute back to the open-data community or otherwise works to meet a non-commercial goal (“unmetered API keys”), and for a fee under our API terms (“subscription API keys”), for example for use in commercial or proprietary applications. We may also choose to grant trial API keys for evaluation and integration of the service.

If you try to get around our restrictions on the use of the OpenSanctions API, for example by applying for multiple trial API keys using different email addresses, or for making multiple requests using different IP addresses, we may block your access to the site without warning and we may take legal action against you.

All non-commercial API keys will require evidence (for example, the URL of the service or website) that you are making good use of the OpenSanctions API. If you cannot supply such evidence (e.g. you are a journalist working on a story that you cannot yet make public), you need to provide us with the reason. We reserve the right to rescind donated API access.

The OpenSanctions data set

The OpenSanctions database is licensed under the Attribution-NonCommercial 4.0 International (CC BY-NC 4.0) license. A plain language summary of the CC-BY-NC 4.0 license is available on the Creative Commons website.

OpenSanctions brings together sanctions lists, lists of politically exposed persons (PEPs), and parties excluded from government contracts in different countries. This data is otherwise difficult to query because it is published in a multitude of semi-structured formats across dozens of government websites. OpenSanctions collects the data and converts it into a well-defined and expressive format for easy use and integration into third-party systems.

OpenSanctions does not claim any rights over the information we receive from our government sources, and attribute them whenever possible. This is known as the “Licensed Material” in the CC-BY-NC 4.0 license.

We do, however, claim rights over our database of this information.

The CC-BY-NC 4.0 license requires you to attribute your use of our database. This is important as it allows us (and in turn the community) to benefit from reuse of our work, and so allows us to continue to provide this service. Citing us in a report or mentioning the source in a newspaper article you write directly supports our work and allows us to create great databases.

If you wish to use the database, or part of the database, without one or more of these restrictions, please contact us for a commercial use license.

Licensing your contributions

We have various parts of our website that allow for you to contribute, whether it be comments, text or anything else. When you contribute, you do so on the basis that the contribution is either your own work or is information freely available in the public domain.

You grant us a non-exclusive, worldwide, perpetual and irrevocable license, with the right to sub-license, over any intellectual property rights (including copyright and database right) you may have in anything you contribute. So long as we continue to make use of your contribution, we agree to make it available via the world wide web or analogous means under a license with at most share-alike and attribution restrictions.

The content of the site that has been produced or generated by OpenSanctions is covered by the Creative Commons Attribution-NonCommercial 4.0 International (CC BY-NC 4.0). This does not cover the database (see above).

Permissions beyond the scope of this license may be available. Please contact us if you think you may need additional permission.

Site software

Please note that site software for our sites do not fall under this license or this copyright policy. We often use open-source software, and for more on the software we use, you should visit their respective homepages.

Some content on this website is presented here as a result of copyright exceptions such as fair dealing, fair use, or other exceptions. Our copyright policy does not cover content used here under these exceptions. As a result, your use of this material may not come under the same legal exception.

We do not restrict your fair use or other copyright exceptions that you may have for our materials covered under this policy.

It is the policy of this website to respect the copyright of others.

If you see anything that you think shouldn’t be here, let us know via info@opensanctions.org.

Trade marks

The site copyright license does not apply to any trade marks, registered or unregistered, used on this site. The site copyright license also does not apply to any copyright that applies to different elements of a trademark, such as a logo or particular work representing the trade mark.

Use of the names OpenSanctions or any site logos are not covered by this license.

Privacy

Please read our detailed Privacy Policy which sets out how we manage your personal data in compliance with the General Data Protection Regulation (“GDPR”) which applies across the European Union.

Feedback

That’s pretty much it. If you have any questions, get in touch.

Thank you. The OpenSanctions team.