Sanctions Explorer: Democratizing Access to OFAC Sanctions Data
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Economic sanctions have become a critical tool in confronting major global geopolitical challenges ranging from nuclear proliferation to terrorism, human rights, corruption, narcotics trafficking, and even wildlife crime. Their impact is felt by countries and companies around the world, from large multinational banks to small humanitarian field organizations. All of these organizations closely follow sanctions designations to stay compliant with regulations in an environment where violations can result in fines of millions of dollars.
The most authoritative source of sanctions information is the data contained within a few different global sanctions lists. Of these, by far the most important is the Specially Designated Nationals (SDN) list maintained and published by the United States Department of Treasury’s Office of Foreign Asset Control (OFAC).
The data contained within the SDN list can help answer key questions. It provides guidance on which specific entities and individuals to avoid financial transactions with, but it can also provide important insights. Which country has the greatest number of sanctioned individuals? What is the breakdown of sanctions on North Korea across all the various sanctions programs? How do different sanctioned entities link to each other? All these answers can offer important observations about the contours of current U.S. foreign policy.
Unfortunately, with the current SDN interface, it is difficult to discover the answers to these questions. While large banks and financial institutions spend millions of dollars on compliance software and analysts to gather their insights, few others have the means to do so. Nonprofits, small businesses, journalists, and academics instead sacrifice significant amounts of time and manpower. Ultimately, while OFAC’s data is publicly available, it lacks accessibility for public use, limiting the opportunity to draw meaningful conclusions from the data.
SanctionsExplorer, an initiative of Archer and C4ADS, is a free, open-source tool that democratizes the accessibility of OFAC sanctions data by providing a unique and evolving toolset for querying and understanding sanctions data.
The SanctionsExplorer platform prioritizes three key goals to efficiently facilitate access to sanctions data:
- Improve the usability of the database and expedite common workflows (such as searching for linked entities or generating reports)
- Provide additional context to maximize the available information for each entity (such as using OFAC’s XML data and displaying press releases that describe justifications behind sanctions)
- Allow for more complex queries and filtering options (including sanction date, nationality, country, and more)
Additional Data and Improved Search
SanctionsExplorer indexes both the SDN and the consolidated non-SDN lists (the SSI, FSE, NS-PLC, etc) by parsing OFAC’s official XML data source, thereby gathering additional information not displayed on the OFAC website. This provides a more comprehensive dataset, including:
- 130+ original-language aliases for entities in Chinese, Japanese, Cyrillic, Arabic, and more
- The date sanctions were implemented and their corresponding legal basis
- Additional linked entities and bi-directional linking (if an entity is linked to another, both will display that link)
- Evaluated accuracy of information, including whether a piece of information was corroborated with a reliable source
Additional Context and New Integrations
The SanctionsExplorer interface has been updated with interactivity and ease-of-use in mind to expedite common workflows. Generating reports is quick and easy — simply run a search, expand the entities of interest, and click the print button to generate a PDF. Search results are also available to download in a CSV format.
When investigating individuals who belong to the same organization, the OFAC website requires a new search for each person — yet each search loses the previous result. With SanctionsExplorer, users can explore linked entities on the same page by clicking through with your original results still visible, removing the hassle of clicking back and forth or open new tabs in order to do a deep dive into an entity’s connections. This makes it easy to directly compare entities or add additional filters to narrow down the search — not to mention that all the results can now be searched on the same page with Ctrl+F to identify even more specific pieces of information.
Finally, integration with press releases provides additional context to search results. Almost weekly, OFAC publishes a press release listing new entities that have been sanctioned as well as context behind those decisions. These statements often describe related organizations as well as justification or a description of the illicit activities, but they are not currently incorporated into the OFAC SDN search.
SanctionsExplorer has collected these press releases and runs a matching algorithm to determine the entities discussed in each. These matches are visible in the search results for each entity, allowing investigators to quickly see the reason that an organization was sanctioned or put together a timeline of sanction events. The press release archive is also directly searchable and can be used for thematic investigations or to discover previously-sanctioned individuals (i.e., those that were delisted).
Advanced Search and Filters
SanctionsExplorer also provides more robust search capabilities by supplying users with powerful search tools and filters. All of OFAC’s existing filters (such as name, program, and address) are available in addition to many more sophisticated options. The “Related to Country” filter can be used to identify entities that are linked to a country through an address, citizenship, or passport (among other identifiers). Filtering by date of sanction can be useful for narrowing down the timeframe of the search results, and vessel- and aircraft-specific filters allow for proper search over attributes like flag and type (e.g. oil tanker, Boeing 727). And filtering by nationality can allow searches for citizens across all sanctions programs. By combining these filters and many others, users can continually drill down on their search results starting from just a sanctions program or country.
In addition, these filters can also perform inexact/fuzzy matching, which allows for small transliteration errors or misspellings. This protects against the types of false negatives illustrated in the Carlos Topete image above.
SanctionsExplorer is just the beginning. As sanctions policy and evasion tactics evolve, the tools used to generate insight from sanctions data will need to keep up. Thus, we have designed SanctionsExplorer as an open-source, ever-evolving platform that will benefit and grow with the feedback of its users.
We plan to continue engineering functionality that provides value to investigators and analysts. We highly prioritize community input when determining how to allocate resources for continued development, so all feedback is considered. There are different avenues of contact available on the website, so please let us know if you’d like to see a feature added or have encountered a bug.
Above all, enjoy trying out our tool. We can’t wait to hear from you.