Preview: Annual Sanctions Review 2019/20
At a glance
More than 9% increase in U.S. sanctions, surprises in comparison to EU/UN Lists
The U.S. OFAC SDN List grew by over 9% to a total volume of 8.062 entries. Sanctions programs with the highest increases were mainly Iran and Venezuela related, but also the Global Magnitsky Program nearly doubled to 195 entries and new programs were introduced as well. At the same time, the volumes of EU and UN Sanctions Lists declined slightly, mainly due to larger removals on the Iraq-related programs. This however does not change the big picture.
Impacts: Higher sanctions risks and more work.
These developments caused more work for sanctions professionals and risk mitigation. The ratio, however, is rather non-linear: Even few additional list entries can cause enormous bottlenecks in screening operations, e.g. if they contain common names. Like in the year before, the high frequency (and unpredictability) of sanctions list changes caused major pain in 2019 – with list amendments on 172 out of 365 days.
Outlook 2020? Headaches will remain — and require close monitoring.
Concerning US sanctions, under the current administration and its foreign policy the trend of the past two years is likely to continue. Developments will remain hard to predict however. This requires a very close monitoring of sanctions list changes and immediate action if needed.
| Annual Sanctions Review 2019 / 2020 www.sanctions-intelligence.com | US OFACSDN | EUConsolidated | UNConsolidated | ∑Total |
|---|---|---|---|---|
| List volume | ||||
| Listed parties (primary names) | 8.062 +9.3% | 2.097 -2.1% | 1.024 -6.5% | 11.183 +5.4% |
| Additional identities / AKA | 12.729 +8.7% | 5.849 -3.7% | 2.616 -1.7% | 21.194 +3.7% |
| Total names to screen | 20.791 +8.9% | 7.946 -3.3% | 3.640 -3.1% | 32.377 +4.2% |
| List dynamics | ||||
Added entries
| 784 | 94 | 11 | 889 |
Changed entries
| 242 | 623 | 778 | 1.643 |
Changed entries
| 79 | 486 | 565 | |
Removed entries | 101 | 138 | 82 | 321 |
Amendments total | 1.127 | 934 | 1.357 | 3.418 |
| Sanctions list changes 2019 | 95 changes | 103 changes | 36 changes | 234 changes | Calender days affected by list changes | 90 days | 100 days | 36 days | 172 days |
| Days between list changes (average) | 4.1 days | 3.7 days | 10.1 days | 2.1 days |
| Affected sanctions programs | 38 programs | 22 programs | 14 programs | 74 programs |
| Country affiliations of listed parties | ||||
| By address | IRN | SYR | IRQ | |
| Top-5 | COL | IRQ | PRK | |
| MEX | PRK | SYR | ||
| SYR | IRN | PAK | ||
| RUS | TUN | IRN | ||
Comments and Definitions
Please note that all figures are preliminary only and work in progress. Methodology is under development and subject to changes. See disclaimer for further information.
Coverage:
Selected sanction programmes involving
US OFAC SDN Lists (through US CSL List),
EU Consolidated Sanction List,
United Nations Sanctions and
United Kingdom HMT Sanction Lists.
Breakdown by sanction programme/regime where possible. Further lists to be added in the future.
Please note that for the analyzed US lists, the aggregated CSL list from the US Department of Commerce was considered, which includes OFAC lists, but has a different structure.
Updates:
On a regular basis for defined lists. Date/time reflects the date of data retrieval from the website of the respective regulator, unless otherwise noted.
Please note that there may be time lags between OFAC published data and their availability in the CSL List of the U.S. Department of Commerce International | Trade Administration (ITA).
Methodology:
Meta data analysis for additions, changes and removals of entries conducted with GCRD methodology (delta comparison), based on sources as indicated above.
Please keep in mind, that a listed party can be subject to different sanctions programs/regimes on a consolidated list. Changes in the sanctions program affiliations of a listed party may be counted as 'change' (and not as additions to or removals from a certain program/regime), unless otherwise noted.
Added
New entry was added to the respective list.
Changed [ I ]
Entry has changed. Meta information on changed datafields in most cases available.
Changed [ II ]
Entry has changed in frequently changing data fields or has formatting changes.
Please note that field content may be inconsistent in terms of format across list versions, resulting in a high number of hits.
Please check possible relevance for your purpose in each case.
Changes may incude for example:
UK HMT Sanction Lists: Leading zeros or leading/trailing blanks in data fields such as 'ni_number', 'passport_details' or 'addresses'.
UN Sanction Lists: Leading zeros or leading/trailing blanks in data fields.
US Sanction Lists: Data field 'Source List Url' (through US CSL List).
EU Sanction Lists: Data field 'pdf_link'.
In addition, these changes may include spelling variations regarding small and capital letters or special characters.
Removed
Entry was removed from a respective list. Date reflects earliest available date/time where entry was not identified anymore.
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