Sanctions lists used by Sanctions360
Countries such as the US and the UK, or a group of countries like the European Union, publish lists of entities that corporations in their jurisdiction should not conduct business with. Entities can be individuals, legal entities such as companies, or marine vessels. These lists of entities are known as sanctions lists.
In Sanctions360, we primarily look at the following sanction lists:
The OFAC SDN list (US)
Sanctions list: The Office of Foreign Assets Control (OFAC) under the US Department of the Treasury publishes the Specially Designated Nationals (SDN) list.
Ownership calculation: Sanctions360 identifies entities that are owned 50% or more by legal entities or individuals on the OFAC SDN sanctions list using ownership information from the Moody's Orbis database. It also identifies entities with less than 50% sanctioned ownership risk.
Ownership definition: The ownership can be direct ownership, single-path indirect ownership, multiple-path indirect ownership, or aggregated ownership as explained in Sanctions360 ownership definitions.
The OFAC Consolidated Non-SDN and SSI lists (US)
Sanctions list: The Office of Foreign Assets Control (OFAC) under the US Department of the Treasury publishes the Consolidated Sanctions list, also known as the Non-SDN list.
The Consolidated Sanctions (Non-SDN) list consists of the following six lists:
Ownership calculation: Sanctions360 identifies entities that are owned 50% or more by legal entities or individuals on the Sectoral Sanctions Identifications (SSI) list using ownership information from the Moody's Orbis database. The 50% ownership rule is applied to all entities on the SSI list irrespective of directive. Note that the 50% ownership rule is only applicable to the SSI list and not the other five sublists.
Ownership definition: The ownership can be direct ownership, single-path indirect ownership, multiple-path indirect ownership, or aggregated ownership as explained in Sanctions360 ownership definitions.
The EU sanctions list (EU)
Sanction list: The EU sanctions list is available online. An EU login is needed for access.
Ownership calculation: Entities that are 50% or more owned by legal entities or individuals on the EU sanctions list using ownership info from the Moody's Orbis database.
Ownership definition: The ownership can be direct ownership, single-path indirect ownership, multiple-path indirect ownership, or aggregated ownership as explained in Sanctions360 ownership definitions.
The OFSI UK sanction list (UK)
Sanction list: The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, and the authority for the implementation of financial sanctions in the UK publishes the OFSI UK sanction list.
Ownership calculation: Sanctions360 identifies entities that are 50% or more owned by entities or individuals on the UK sanctions list using ownership information from the Moody's Orbis database.
Ownership definition: The ownership can be single-direct or single-path indirect ownership as explained in Sanctions360 ownership definitions.