How civil society organisations can use OpenSanctions to conduct screening checks

This is particularly relevant for organisations that receive funding from the US government, e.g. through USAID and the Department of State.

These requirements exist to ensure that CSOs don’t hire or contract persons and companies which have been excluded from receiving government funds due to misconduct, or that money is being handed to groups that have been designated as terrorists or national security risks.

Representatives at the UN in Geneva (Foto: UN Press)

Unfortunately, these screening checks often lead into a dense forrest of policy acronyms: CSOs are required to check SAM, OFAC SDN, sometimes also CSL, UFLPA, various DoD lists - and that’s just for the US. The UK and EU have their own blocking regimes and lists. However, with the help of OpenSanctions, this process can be streamlined and made more efficient.

In this technical guide, we'll walk you through how to leverage OpenSanctions effectively to ensure compliance with regulatory mandates.

What is OpenSanctions?

OpenSanctions is an open source database designed to facilitate sanctions and watchlist screening. It brings together data from hundreds of individual watchlists and makes it easy to search all of them at the same time. While OpenSanctions is sustained by commercial revenue from data licensing, we also have a public interest mission and our system is free to use for non-profits and the media.

In short: we’re building a commercial-grade screening product, and its open nature empowers CSOs with the tools they need to uphold ethical standards and comply with funder obligations.

Getting Started

1. Access the database: Visit the OpenSanctions screening tool to access the data. No registration or subscription is required, making it accessible to all.
2. Enter search criteria: In the screening tool, input the full name of the individual or entity you want to screen. The results will be more precise if you enter additional details such as the date of birth or nationality of the person, or the registration number and jurisdiction for legal entities.
3. Review search results: OpenSanctions will generate a list of matches based on your search criteria. Take the time to review these results carefully. While the screening tool enables you to search only inside of specific watchlists, we recommend searching all lists (”OpenSanctions Default”) and discarding irrelevant results after the fact.
4. Match analysis: For each search match, OpenSanctions provides a profile page with detailed information regarding the match. This includes relevant identifiers, sanctions program details, and associated entities. On top of that, profiles link to source websites for each entity when they’re available so you can find more information on the website of the relevant government authority.
5. Assess risk level: Evaluate the risk associated with each match based on the provided information. This may involve conducting further due diligence (e.g. if you’re uncertain that the matching entity is the same as the counterparty you’re screening, or if the match is from a list you’re not directly required to screen against by your funders) or refraining from engaging with the individual or entity.
6. Document your searches: Maintain thorough records of your screening activities, including search queries and results. Documentation is crucial for demonstrating compliance with regulatory requirements. All result pages on OpenSanctions are designed to be exported as PDFs so you can use your browser’s “Print/Save as PDF” function to create a record for your files.

Data sources primer

Here’s some of the key watchlists you might come across when using OpenSanctions to screen your contractors and vendors:

• SAM (System for Awards Management) is the central database of the US federal government on procurement. Its exclusion list defines a set of people and companies that may not receive US funds. The SAM list is an aggregate information from many different US authorities. Conducting SAM checks is the central requirement for US-funded CSOs.
• OFAC (Office of Foreign Assets Control) is a unit within the US Treasury that defines and publishes the primary US sanctions list, called SDN. OFAC also releases a bundle of several related watchlists, called the Consolidated list.
• The US International Trade Administration publishes the Consolidated Screening List, which aggregates information about export prohibitions.
• Beyond these well-known lists, the US government publishes a vast array of smaller lists, addressing issues such as Uyghur forced labour, financial crime enforcement, securities fraud, etc. etc.
• In the UK, the Office for Financial Sanctions Implementation (OFSI) publishes lists of financial sanctions and investment bans; alongside the main UK sanctions list.
• For Europe, a Consolidated List is published by the European Commission, but it doesn’t include several sanctions regimes that we aggregate separately, and various member states implement additional national lists (e.g. Czechia, Belgium, Latvia, Lithuania).
• The international development banks (World Bank, EBRD, IADB, ADB, AfDB) release debarment lists, which designate entities excluded from receiving their funds for a period of time.
• Watchlists such as the INTERPOL Red Notices, DEA Fugitives, Europol Most Wanted, NCA Most Wanted indicate persons linked to criminal behaviour.

OpenSanctions updates the information from all of these sources on a daily basis, and core sanctions lists are updated more often than that.

Using our API

While this guide has focussed on using our website to conduct screening checks, we also provide free API keys to non-profit organisations for bulk screening. You can use the API to systematically cross-reference donor databases, CRM data, or other counterparties. CSOs working in the anti-corruption field can also benefit from the OpenSanctions API to conduct investigative research. If you want to use our API, please get in touch.

Conclusion

Compliance with regulations is essential for civil society organisations that receive funding from government bodies. By utilising OpenSanctions for sanctions and watchlist screening, you can streamline your compliance efforts and ensure adherence to regulatory requirements.

What’s more important, though, is the actual insight you may get from conducting screening: the broad set of risk information sources included in our database will provide you with a heads-up if you’re about to engage with a group or person that is subject to risk factors.

It’s always better to know.