PEPs and Sanctions Sources

This article provides an overview of AML HQ’s PEP/Sanctions service.

Alongside Politically Exposed Persons (PEPs), Businesses and State-Owned Enterprises (SOEs), Regulatory Enforcement Lists and Reputational Risk Exposure (RRE), the Sanctions Content forms an integral part of our service. We use the term “Sanctions” as an umbrella term covering a wide array of restrictive measures. These measures range from multilateral or global programmes (for example, UN, EU, OFAC) to unilateral sanctions as enacted and enforced by national governments either as commitment to upholding international law or in the pursuit of more specific foreign policy objectives.

The United Nations (UN) imposes financial sanctions and requires member states to implement them through resolutions passed by the UN Security Council (UNSC).

The United Nations (UN) imposes financial sanctions and requires member states to implement them through resolutions passed by the UN Security Council (UNSC). The UN Security Council can decide to act to preserve or restore international peace and security under Chapter VII of the UN Charter. Such sanctions may target governments of third countries or non-state entities and individuals (such as terrorist groups and terrorists). They may range from comprehensive economic and trade sanctions to more targeted measures comprising arms embargoes, other specific or general trade restrictions (import and export bans), financial restrictions, restrictions on admission (visa or travel bans), or other measures, as appropriate.

There are currently 16 UN Resolutions that determine current UNSC Sanctions.

The European Union implements financial sanctions through EU regulations which have direct legal effect in the UK and all other EU member states.

The European Union implements financial sanctions through EU regulations which have direct legal effect in all EU member states. Article 215 of the Treaty on the Functioning of the European Union (TFEU) provides a legal basis for the interruption or reduction, in part or completely, of the Union’s economic and financial relations with one or more third countries (that is, countries outside the EU) to achieve the objectives of the Common Foreign and Security Policy (CFSP). The sanctions imposed by the EU are either on an autonomous basis or implemented on the strength of binding resolutions of the Security Council of the United Nations Sanctions. Where the sanctions are introduced on an autonomous basis, these reflect the foreign and security policy of the European Union member states rather than that of the international community as evident in the United Nations Resolutions. There are currently 38 Current EU Sanctions.

The United States Treasury’s Office of Foreign Assets Control issues US sanctions. OFAC manages a range of programmes in addition to country-based regimes.

The United States Treasury’s Office of Foreign Assets Control issues US sanctions. OFAC manages a range of programmes in addition to country-based regimes and also issue sanctions to specifically combat the trade of drugs through Counter Narcotics Trafficking Sanctions. The Patriot Act introduced in October 2001 is a major piece of legislation that empowers certain US government agencies to implement measures to enhance national security. The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury is entrusted with the enforcement of economic and trade sanctions and also responsible for the periodic publication of a consolidated list containing the names and identification details of targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, threats to national security, foreign policy, or economy of the United States who are subject to financial restrictions.

• Specially Designated Nationals (SDN) List • OFAC Sanctions Programs of which there are 48 programs.

HM Treasury implements UN and EU financial sanctions through its Office of Financial Sanctions Implementation (OFSI) and makes designations under domestic programmes.

HM Treasury implements UN financial sanctions through its Office of Financial Sanctions Implementation (OFSI) and makes designations under multiple domestic programmes. OFSI is the government agency in charge of implementing financial sanctions including targeted asset freezes and restrictions on financial services. Breaches of UK financial sanctions are criminal offences, punishable upon conviction for up to 7 years in prison. There are both civil and criminal enforcement options to remedy breaches of financial sanctions. Law enforcement agencies may consider prosecution for breaches of financial sanctions. The monetary penalties regime created by the 2017 Act provides an alternative to criminal prosecution for breaches of financial sanctions legislation. OFSI can impose penalties for sanction breaches of up to £1 million or 50% of the value of the breach – whichever is higher.

• UK Sanctions List which numbers 35 • Consolidated list of financial sanctions targets (Asset Freeze Target List)

Other countries are issuing sanctions, particularly to comply with those imposed by the United Nations and the European Union.

In addition to UN, EU, US OFAC and UK HMT OFSI sanctions, many other countries are issuing sanctions, particularly to comply with those imposed by the United Nations and the European Union (for its members), but also in pursuit of own foreign policy objectives. For instance, Canadian sanctions laws implement UNSC sanctions regimes as well as an autonomous sanctions program under the Special Economic Measures Act. Similarly, Australia is obliged to implement UNSC sanctions regimes as a matter of international law; however, the Australian Department of Foreign Affairs and Trade does also implement autonomous sanctions regimes which may supplement UNSC sanctions regimes or be separate from them. In the US, in addition to OFAC, various legal authorities are imposing sanctions, including the Bureau of International Security and Non-proliferation (ISN) which is the arm of the State Department responsible for managing a broad range of non-proliferation and counter-proliferation functions; BIS aims to prevent the spread of weapons of mass destruction (nuclear, chemical, and biological weapons) and their delivery systems. Also, pursuant to the USA Patriot Act, FinCEN’s “Section 311 Special Measures,” identifies jurisdictions and entities which are of “primary money laundering concern”. Belgium, apart from implementing UN and EU sanctions, has also taken measures to draw up a national list, pursuant to the Royal Decree of 28 December 2006 with regards to specific restrictive measures against some persons and entities within the framework of the fight against terrorism financing, confirmed by the Article 155 of the Law of 25 April 2007. The Royal Decree requires to freeze without any delay all funds and economic assets of the persons and entities mentioned in the national list and forbids to put, directly or not, funds and economic assets at disposal of these persons and entities. In Switzerland, according to the Embargo Act, the Confederation may enact compulsory measures to implement sanctions that have been ordered by the UN, by the Organisation for Security and Cooperation in Europe (OSCE) or by country’s most significant trading partners and which serve to secure compliance with international law, and in particular the respect of human rights.

We regard sanctions coverage as one of our most important responsibilities, given that sanctions are absolute requirements depending on the jurisdictions where are customers are based and the currencies they transact in.

Our service has access to a sanctions team that is manned around the clock with a dedicated team of multilingual area specialists who monitor all sanctions for new releases daily and on a rolling schedule as well as being subscribed to various news and email alerts issued directly by the sanctioning bodies. Alongside this sanctions team, analysts and senior matter experts from the content team also screen local national sources daily as well as a wide selection of regulatory bodies and watchlists from all around the globe.

A wide range of sanctions websites are constantly monitored and relevant content captured and delivered in dedicated queues for expedient data processing.

All of the content creation and update procedures are subject to strict auditable quality assurance procedures and every effort is made to avoid errors, missing data fields or the duplication of profiles and to ensure that as a provider, we are timely and accurate in our gathering and sharing of sanctions and regulatory enforcement content.

In terms of data acquisition, all sanction sources are screened daily and profiles created or updated promptly. The processing time for new sanction releases varies depending on the number of names and the amount of information available for each profile; however, the expectation is that the update is completed within 24 hours. In most cases the update will be completed within 30 minutes to several hours of release.

Sanctions

Sources from the most updated releases of UN, EU, OFAC, OFSI sanctions and watch lists, world-wide law enforcement agencies, financial regulators, original document of press articles and other national or unilateral sanctions.

Politically Exposed Persons (PEPs)

Over 1.4 million profiles of PEP and their associated family members, business and business partners.

Global Data

Data from over 14,000 global sources with 4 million profiles of worldwide major international sanctions lists, PEPs, SOEs, REPs, and Local Adverse Media.

Europe sanctions sources list

Europe Belgian Federal Public Service Finance - National Financial Sanctions Belgium

Europe EU - Afghanistan European Union

Europe EU - Al Qaeda and ISIL (Da’esh) European Union

Europe EU - Belarus European Union

Europe EU - Bosnia and Herzegovina European Union

Europe EU - Burundi European Union

Europe EU - Central African Republic European Union

Europe EU - Chemical Weapons European Union

Europe EU - China European Union

Europe EU - Cyber Attacks European Union

Europe EU - Democratic People’s Republic of Korea (North Korea) European Union

Europe EU - Democratic Republic of Congo European Union

Europe EU - Guinea-Bissau European Union

Europe EU - Haiti European Union

Europe EU - Human Rights European Union

Europe EU - Iran European Union

Europe EU - Iraq European Union

Europe EU - Lebanon European Union

Europe EU - Libya European Union

Europe EU - Mali European Union

Europe EU - Moldova European Union

Europe EU - Montenegro European Union

Europe EU - Myanmar (Burma) European Union

Europe EU - Nicaragua European Union

Europe EU - Republic of Guinea (Conakry) European Union

Europe EU - Russian Federation European Union

Europe EU - Serbia European Union

Europe EU - Somalia European Union

Europe EU - South Sudan European Union

Europe EU - Sudan European Union

Europe EU - Syria European Union

Europe EU - Terrorist Groups (Foreign Terrorist Organisations) European Union

Europe EU - Tunisia European Union

Europe EU - Turkey European Union

Europe EU - Ukraine European Union

Europe EU - USA (United States of America) European Union

Europe EU - Venezuela European Union

Europe EU - Yemen European Union

Europe EU - Zimbabwe European Union

Europe Ministry of Economy, Finance and the Recovery, General Directorate of Treasury - Individuals and Entities subject to restrictive measures France

Europe - Government of Georgia - Otkhozoria-Tatunashvili List Georgia

Europe - Committee on Financial Monitoring - Ministry of Finance - List of organizations and persons associated with the financing of terrorism and extremism Kazakhstan

Europe - State Financial Intelligence Service under the Government of the Kyrgyz Republic - Consolidated Sanctions List Kyrgyzstan

Europe - Ministry of the Interior of the Republic of Lithuania - Financial Crime Investigation Service Lithuania

Europe - Ministry of Foreign Affairs and Trade Promotion - Sanctions Monitoring Board - List of sanctioned entities Malta

Europe - Monaco Council of Government - Entities designated in accordance with Sovereign Order No. 15.321 Monaco

Europe - Dutch Government (Rijksoverheid) - National terrorism sanctions list (Nationale sanctielijst terrorisme) Netherlands (the)

Europe - Ministry of the Interior and Administration - List of persons and entities subject to sanctions Poland

Europe - Federal Security Service (FSB) - Terrorist List Russian Federation (the) Europe Russian Government - Decree of the President of the Russian Federation of October 22, 2018 (Sanctions against Ukraine) Russian Federation (the) Europe Russian Government - Economic Measures against Unfriendly Nations Russian Federation

Europe - Directorate for the Prevention of Money Laundering, Ministry of Finance - Domestic List of Terrorists Serbia

Europe - State Secretariat for Economic Affairs (SECO) of Switzerland - Sanctions List Switzerland

Europe - National Bank of Tajikistan - Designated Terrorists Tajikistan

Europe - Ministry of Interior of Turkey - Turkey Most Wanted Terrorists Turkey

Europe - Ministry of Treasury and Finance (MASAK) - Asset Freeze Lists Turkey

Europe - National Security and Defense Council of Ukraine

Europe HMT/OFSI - Afghanistan

Europe HMT/OFSI - Belarus

Europe HMT/OFSI - Bosnia and Herzegovina

Europe HMT/OFSI - Burundi

Europe HMT/OFSI - Central African Republic

Europe HMT/OFSI - Chemical Weapons

Europe HMT/OFSI - Counter Terrorism

Europe HMT/OFSI - Cyber

Europe HMT/OFSI - Democratic People’s Republic of Korea

Europe HMT/OFSI - Democratic Republic of the Congo

Europe HMT/OFSI - Global Anti-Corruption

Europe HMT/OFSI - Global Human Rights

Europe HMT/OFSI - Guinea

Europe HMT/OFSI - Haiti

Europe HMT/OFSI - International Counter Terrorism

Europe HMT/OFSI - Iran (Human Rights)

Europe HMT/OFSI - Iran (Relating to Nuclear Weapons)

Europe HMT/OFSI - Iraq

Europe HMT/OFSI - ISIL (Da’esh) and Al-Qaida organizations

Europe HMT/OFSI - Lebanon (Assassination of Rafiq Hariri and others)

and Northern Ireland (the)

Europe HMT/OFSI - Libya

Europe HMT/OFSI - Mali

Europe HMT/OFSI - Myanmar

Europe HMT/OFSI - Nicaragua

Europe HMT/OFSI - Republic of Guinea-Bissau

Europe HMT/OFSI - Russia

Europe HMT/OFSI - Somalia

Europe HMT/OFSI - South Suda

Europe HMT/OFSI - Sudan

Europe HMT/OFSI - Syria

Europe HMT/OFSI - UK Freezing Orders

Europe HMT/OFSI - Unauthorised Drilling Activities

Europe HMT/OFSI - Venezuela United Kingdom

Europe HMT/OFSI - Yemen

Europe HMT/OFSI - Zimbabwe

Europe - Department for Combating Economic Crimes under the General Prosecutor's Office of the Republic of Uzbekistan - List of individuals and organisations participating or suspected of participating in terrorist activities [Foreign citizens] Uzbekistan.

Europe - Department for Combating Economic Crimes - Individuals participating in terrorist activities (UN duplicates) Uzbekistan.

Europe - Department for Combating Economic Crimes - Organisations participating in terrorist activities (UN duplicates) Uzbekistan.

Americas sanctions sources list

Americas Public Registry of Individuals and Entities linked to Acts of Terrorism and its Financing (Registro Publico de Personas y Entidades Vinculadas a Actos de Terrorismo y su Financiamiento, REPET) Argentina

Americas Global Affairs, Government of Canada

Americas Public Safety, Government of Canada

Americas OFAC - Balkans-related Sanctions

Americas OFAC - Belarus Sanctions

Americas OFAC - Burma Sanctions

Americas OFAC - Burundi Sanctions

Americas OFAC - Central African Republic

Americas OFAC - Chinese Military Companies Sanctions

Americas OFAC - Consolidated Sanctions List

Americas OFAC - Counter Narcotics Trafficking Sanctions

Americas OFAC - Counter Terrorism Sanctions

Americas OFAC - Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA)

Americas OFAC - Cuba Sanctions

Americas OFAC - Cyber Related Sanctions

Americas OFAC - Democratic Republic of the Congo-related Sanctions

Americas OFAC - Ethiopia-Related Sanctions

Americas OFAC - Foreign Interference in a United States Election Sanctions

Americas OFAC - Foreign Sanctions Evaders List (FSE List)

Americas OFAC - Global Magnitsky Sanctions

Americas OFAC - Hong Kong Related Sanctions

Americas OFAC - Hostages and Wrongfully Detained US Nationals Sanctions

Americas OFAC - Iran Sanctions

Americas OFAC - Iraq-related Sanctions

Americas OFAC - Lebanon-related Sanctions

Americas OFAC - Libya Sanctions

Americas OFAC - List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List)

Americas OFAC - Magnitsky Sanctions

Americas OFAC - Mali Related Sanctions

Americas OFAC - Nicaragua Sanctions

Americas OFAC - Non SDN Iranian Sanctions List

Americas OFAC - Non-Proliferation Sanctions

Americas OFAC - Non-SDN Chinese Military-Industrial Complex Companies List

Americas OFAC - Non-SDN Menu-Based Sanctions List

Americas OFAC - Non-SDN Palestinian Legislative Council List

Americas OFAC - North Korea Sanctions

Americas OFAC - PEESA-EO - Protecting Europe's Energy Security Act Executive Order

Americas OFAC - Protecting Europe's Energy Security Act (PEESA)

Americas OFAC - Rough Diamond Trade Controls

Americas OFAC - Russian Harmful Foreign Activities

Americas OFAC - Sectoral Sanctions Identifications (SSI) List

Americas OFAC - Somalia Sanctions

Americas OFAC - South Sudan Related Sanctions

Americas OFAC - Sudan and Darfur Sanctions

Americas OFAC - Syria Related Sanctions

Americas OFAC - Syria Sanctions

Americas OFAC - Transnational Criminal Organizations

Americas OFAC - Ukraine/Russia Related Sanctions

Americas OFAC - Venezuela-Related Sanctions

Americas OFAC - Yemen Related Sanctions

Americas OFAC - Zimbabwe Sanctions

Americas US State Department - Non-Proliferation

UN International level sanctions sources list

International Level Asian Development Bank (ADB) - Sanctions List International Level

International Level Resolution 751 (1992) concerning Al-Shabaab United Nations

International Level Resolutions 1267 (1999) 1989 (2011) and 2253 (2015) concerning Islamic State in Iraq and the Levant (Da’esh), Al-Qaida and associated individuals, groups, undertakings, and entities.

International Level Resolution 1518 (2003) concerning Iraq and Kuwait

International Level Resolution 1533 (2004) concerning the Democratic Republic of the Congo

International Level Resolution 1591 (2005) concerning the Sudan

International Level Resolution 1636 (2005) concerning Lebanon

International Level Resolution 1718 (2006) concerning Democratic People's Republic of Korea

International Level Resolution 1970 (2011) concerning Libya

International Level Resolution 1988 (2011) concerning Taliban and associated Individuals and Entities

International Level Resolution 2048 (2012) concerning Guinea-Bissau

International Level Resolution 2127 (2013) concerning the Central African Republic

International Level Resolution 2140 (2014) concerning Yemen

International Level Resolution 2206 (2015) concerning South Sudan

International Level Resolution 2231 (2015) on Iran Nuclear Issue

International Level Resolution 2374 (2017) concerning Mali

International Level Resolution 2653 (2022) concerning Haiti