Sanctions programs are the specific government policies that form the legal basis for designating individuals, companies, vessels, or other entities as sanctioned.
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Sanctions programs are the specific government policies that form the legal basis for designating individuals, companies, vessels, or other entities as sanctioned.
Each program defines a scope and a set of measures that the issuing authority imposes on the sanctioned target.
Programs describe the legal and political basis for designations. While dataset metadata is source-centred and describes what the dataset contains and its limitations, program descriptions are law-centred and provide more context on the mechanism behind designated entities.
In large consolidated lists such as those published by the EU, the UN Security Council or the US Office of Foreign Assets Control (OFAC), a single dataset bundles multiple designation regimes. Programs distinguish between them, typically by geographical or thematic scope (counter-terrorism, cyber, etc).
For example, the US Trade Consolidated Screening List includes dozens of programs, including the BIS Denied Persons List and BIS Military End-Users List. Similarly, the EU Financial Sanctions Files (FSF) dataset contains sanctions related to Ukraine (program ID EU-UKR), sanctions related to the Taliban (program ID EU-AFG), and many more.
We sometimes use the term program a bit more broadly, to identify sub-lists inside a single data source. For example, the ICIJ Offshore Leaks database includes the Panama Papers, Paradise Papers, and Pandora Papers as programs.
We maintain a custom taxonomy of sanctions programs to bring order to the complex world of sanction regimes. Program descriptions serve as in-depth metadata, and individual entities in the database are increasingly linked to the programs they are designated under using the programId property. Together with the programs metadata JSON, this can be used to include program descriptions in applications consuming the data, showing the exact legal or policy basis for a sanction.
The same person might be listed under multiple programs if they are sanctioned for different reasons by different authorities or countries.
Use programs when you need to distinguish between different regimes in a large consolidated list, or to surface more information about a sanction in a user interface. A directory of sanctions programs is available on our website and at https://data.opensanctions.org/meta/programs.json.
Sanctions Program Mapping: Better Transparency and Navigation
Below is an excerpt from a Sanction entity:
{
"id": "ch-seco-339c6adef0260af3dd08587f16fdecea1c569192",
"schema": "Sanction",
"properties": {
"programUrl": ["https://www.seco.admin.ch/seco/de/home/Aussenwirtschaftspolitik_Wirtschaftliche_Zusammenarbeit/..."],
"program": ["Ordinance of 4 March 2022 on measures related to the situation in Ukraine (RS 946.231.176.72), annexes 2, 8, 9, 10, 11, 12,13, 14, 14a, 15, 15a, 15b, 25 and 33"],
"country": ["ch"],
"authority": ["State Secretariat for Economic Affairs"],
"programId": ["SECO-UKRAINE"]
}
Only programId contains a reference to our custom taxonomy. All other fields (in this excerpt programUrl, program, authority) are usually derived directly from the source. For more information, see the full documentation on the Sanction schema.
[EU-RUS] (EU Sanctions against Russia)ip for "Cyberspace")Our programs taxonomy uses a controlled vocabulary to describe the scope of measures imposed by a sanction program. Like the programs taxonomy itself, they are a necessarily imperfect attempt to bring order to a complex domain.
Measures are grouped into three broad categories based on what they restrict:
Restrictions on the movement, transfer, or supply of physical goods and equipment.
Blanket prohibition on arms/military equipment to a country or regime. Country-wide scope only. If targeted at specific entities, we use Arms restrictions instead.
Prohibitions on the supply, sale, transfer, or procurement of arms, ammunition, military equipment, and related services (technical assistance, training, financing, brokering). Scope and direction defined by the applicable regime.
Restrictions on the export, re-export, or transfer of dual-use goods, technology, software, or luxury goods to specified destinations, end-users, or end-uses. Covers outright bans and licensing requirements. Military-list items fall under Arms restrictions.
Prohibitions on importing goods originating in or consigned from a sanctioned country, territory, or sector. Covers commodity-specific bans (oil, coal, gold, diamonds, charcoal, seafood, textiles, etc.) and origin-based prohibitions (e.g. forced-labour import bans).
Port access bans, airspace closures, overflight prohibitions, ship-to-ship transfer bans, vessel deflagging, aircraft landing prohibitions, and prohibitions on maritime/aviation services (crewing, classification, bunkering, insurance of vessels/aircraft).
Restrictions on financial assets, transactions, capital flows, and funding.
Suspension or reduction of foreign aid, development funding, or multilateral lending to a country or territory.
Freezing of funds, financial assets, and economic resources owned or controlled by a designated person or entity, and the prohibition on making funds or economic resources available to or for their benefit. Includes US-style blocking (OFAC SDN). Does not cover broader financial services or market access restrictions — those fall under Financial restrictions.
Restrictions on financial transactions, services, or access beyond a designated-person asset freeze. Systemic: SWIFT disconnection, correspondent banking bans, capital-market access bans, sovereign debt restrictions, deposit caps. Entity-level: transaction-processing bans, financing/lending prohibitions, insurance/reinsurance bans, securities dealing restrictions.
Prohibition on new investment (equity, joint ventures, capital contributions, acquisition of ownership interests) in a sanctioned country, territory, sector, or entity. Targets future capital formation, not existing assets (Asset freeze) or lending (Financial restrictions).
Prohibition on satisfying claims by designated persons or the government of a sanctioned country, through litigation, arbitration, or otherwise, in connection with contracts or transactions affected by sanctions.
Restrictions on the provision of services or access to programs and jurisdictions.
Exclusion from government procurement, contracts, or programs (e.g. Medicaid/Medicare exclusions, World Bank debarment, SAM.gov).
Prohibition on providing professional, technical, or advisory services (legal, accounting, auditing, IT, consulting, engineering, advertising, trust/company formation) to sanctioned countries or persons. Where services are ancillary to a controlled-goods transfer, we use the applicable goods category. Where a services prohibition exists only as a component of a goods restriction (e.g. technical assistance for arms as part of the arms embargo), we use the goods category. We use Services ban for standalone prohibitions on professional/advisory services with no physical-goods component.
Prohibition on entry into or transit through the territory of the sanctioning jurisdiction. Designated natural persons only.
Restrictions targeting an entire economic sector (energy, defence, extractives, technology). We use this when the measure does not reduce to a single more specific category above, and prefer the specific category where applicable. If a sectoral measure can be fully described as an export control, import restriction, investment ban, or financial restriction, we use the specific category. Sectoral sanctions is for measures defined at sector level that cannot be decomposed without loss of meaning.
An asset freeze follows the person — it freezes their existing assets and prohibits making funds available to them. Financial restrictions follow the activity — they prohibit categories of transactions regardless of individual designation.
Arms restrictions cover items on military lists (munitions, weapons systems, military equipment). Export control covers dual-use goods, technology, and luxury goods. Where a regime restricts both, we use both. Internal repression equipment (surveillance tech, crowd control gear) is Export control, not Arms restrictions.
Import restrictions covers any prohibition on bringing goods into the sanctioning jurisdiction from a target. This includes commodity embargoes (e.g. EU oil import ban on Russia), resource-origin bans (Kimberley Process), and forced-labour import prohibitions (US UFLPA, Section 307 Tariff Act).