Different kinds of listed subjects
Depending on the authority and regime, a designation may identify an individual, company, organization, group, vessel, aircraft or another form of property. Sanctions Sleuth currently separates searches for people from searches for legal entities. It is not designed to determine ownership and control, screen vessels or aircraft as separate subject types, or decide whether an unlisted organization is legally affected through its relationship with a listed person.
Why a subject may be designated
The grounds come from the relevant legal regime. They can concern conduct, responsibility for particular actions, support for another designated subject, an official position, ownership or control, activity within a targeted sector, or criteria established by a United Nations designation. The wording and legal test are authority-specific. A short label in an app cannot replace the authority's statement of reasons or governing instrument.
How an official record identifies someone
A name is only the starting point. A record may include:
- primary names, previous names and aliases;
- alternative spellings and non-Latin scripts;
- dates and places of birth, nationality and gender;
- addresses, positions and occupations;
- passport, national identity, registration or tax numbers;
- programme, regime and official reference identifiers.
Not every record contains every field. Missing information can make a common-name match especially difficult to resolve. Conversely, a difference in one field should be investigated rather than treated automatically as conclusive, because official records can contain incomplete, approximate or historical data.
Amendments, corrections and removal
Authorities update records for several different reasons. A correction may fix an administrative detail. A variation or amendment may change the identifiers, reasons or measures while leaving the designation in force. A revocation, delisting or removal ends a particular listing after the responsible decision-making process. The terminology is not interchangeable across every authority.
Removal can follow a periodic review, a successful reconsideration request, a court judgment, a change in circumstances, expiry of a measure, or a corresponding UN decision. It does not necessarily erase the historical fact that a designation existed, and removal by one authority does not automatically remove a separate designation maintained by another.
Ownership and control require separate analysis
Some sanctions rules can affect property or organizations owned or controlled by a designated person even when the organization is not named in the downloaded list. Screening a company name alone therefore cannot establish the full sanctions position. Applicable authority guidance and professional assessment may require examination of ownership, control, counterparties and the proposed activity.
Do not identify a person from a name alone. Compare the official reference and as many independent identifiers as the record and your reliable information provide.