Sanctions lists covered 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 under Directives 1, 2, and 3 on the Sectoral Sanctions Identifications (SSI) list, and 33% or more by entities under Directive 4, using ownership information from the Moody's Orbis database. Note that this calculation only applies to entities on the SSI list and not the other five sub lists under OFAC Non-SDN.
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: Sanctions360 identifies entities that are owned 50% or more 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 owned more than 50% 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.
Additional sanction lists
In addition to the primary sanctions lists described previously, Sanctions360 covers directly sanctioned entities on the following lists if found in the Moody's Orbis database. No ownership calculations are applied to these entities to determine sanctions by extension.
These sanctions lists are not included in the S360 file.
Sanctions360 only highlights if these sanctions lists have directly sanctioned an entity or individual. There are no ownership calculations applied to these entities for the purpose of capturing if an entity is sanctioned by extension.