Frequently asked questions

The primary source of EU sanctions data in OpenSanctions is the EU Financial Sanctions Files dataset, which is published by European Commission (EC, DG FISMA). However, uniquely amongst the global sanctions authorities, the consolidated database is not produced by the same body which mints new sanctions designations. This task falls to the European Council, which publishes new sanctions as part of the Official Journal of the European Union (OJEU) in text form. The EC then republishes them in their official database - after some delay.

This delay - sometimes as long as 21 days - has caused a major headache for financial institutions and regulated entities, who have to fear facilitating sanction-linked payments because their screening systems have not included updated data.

The only alternative is to manually track the publication of new sanctions designations in the OJEU. To do so, one has to track amendments to over 120 different EU regulations linked to “restrictive measures” (sanctions). That’s why we’ve created a special datasets, called EU Council Official Journal Sanctioned Entities that includes new sanctions as soon as they’ve been published.

EU regulated entities should consider using the EU Sanctions data collection to screen the EU FSF, Journal-only sanctions, and the national sanctions databases of EU member states like France and the Czech Republic all at the same time.

How this works

To efficiently track OJEU sanctions updates, we have built a continuous monitoring system that tracks updates in the journal, specifically scanning for changes related to EU sanctions-related regulations. We begin by querying for legislation related to sanctions listed in the unofficial API of the EU Sanctions Map, assuming it is complete and up to date. From there, using a combination of web scraping and SOAP-based querying (leveraging the EUR-Lex web service), the system continuously monitors newly published legal documents.

The first step is to identify and extract the CELEX number of the original act when provided with a URL that may link to a consolidated version of the act (a document that combines the original legislation with all its subsequent amendments and corrections into a single, easy-to-read format). However, we are interested in retrieving the original document.

Each EU legal document gets a unique CELEX number, which is used as the key identifier for that specific piece of legislation. It typically consists of a prefix that indicates the type of document (such as a regulation or directive), followed by a year and a sequential number assigned to that act.

02024D0254-20240202

Once we get the CELEX number, the system queries the EUR-Lex service, which houses EU legal documents. Then, tailored search queries come into play, allowing us to access only relevant legal texts, including regulations, directives, and any associated amendments.

When we identify a new document, the system checks if it’s related to any existing sanctions regimes by comparing its CELEX number with those we’ve already seen. If the number is new, we send an alert to our public Slack channel, #eu-journal, and add the CELEX number to our list of known documents to avoid duplicate alerts.

To ensure smooth operation, we’ve taken special care to trigger alerts only once for each new document. However, we also have a separate system in place that will notify us if there’s an error, ensuring no new documents are missed.

By keeping an eye on these updates, we can quickly review the document and manually transcribe the compliance-related sanctions information into our database - within ca. three hours after it’s published.