# Third-Country Sanctions Monitor: method note, version 1

The Geopolitical Economist · published 8 October 2026 · [the monitor](https://geopoliticaleconomist.com/research/trackers/third-country-sanctions)

This note describes the measures database behind the monitor: what is in it, how each official list was read and coded, how every record was checked, and what version one leaves out. It is not legal advice. A listing records an official action by the authority named; it is not a finding by this publication.

Built 5–6 October 2026 and revised after four independent reviews (programme coding, country coding, completeness and trade figures). The record counts by authority, country, year, type, EU source and programme, the counts of people, address precision and same-name listings, the removals, the check results and the press-release figures are printed by `scripts/summary_tables.py` from the data files; figures from the review rounds are not. The scripts in `scripts/` rebuild the database from the official files.

## What is in it

- **Scope.** US, EU and UK measures under the Russia and Iran programmes, dated 1 January 2024 or later, against a firm or person with an address in India, the UAE, Türkiye, China or Hong Kong.
- **One record is one measure against one target.** A third country is any country other than Russia, Iran and the one imposing the measure.
- **No address.** Where the authority gives no address, a place of registration, company number or principal place of business that it states counts (4 records, marked `registration only`).
- **1,674 records:**
  - US (OFAC SDN List): 1,159, of which 3 are Russia or Iran tags added to an existing entry
  - EU: 242, of which 73 are asset freezes from the EU consolidated file, 12 are asset freezes read from an act the file lacks, and 157 are Annex IV export-control listings
  - UK (UK Sanctions List): 273

| Country | US | EU | UK | Total |
|---|---|---|---|---|
| India | 96 | 14 | 6 | 116 |
| United Arab Emirates | 326 | 48 | 167 | 541 |
| Türkiye | 153 | 36 | 9 | 198 |
| China | 247 | 77 | 45 | 369 |
| Hong Kong | 337 | 67 | 46 | 450 |
| Total | 1,159 | 242 | 273 | 1,674 |

- **By year:** 513 in 2024, 600 in 2025 and 561 in 2026 (to the list dates below).
- **By type:** listing 1,506; listing re-imposed 8 (EU, 29 September 2025); export control 157 (EU Annex IV); programme added 3 (US).
- **People:** 157 records are individuals.
- **By programme, India:** US Iran 69, US Russia 27, EU Russia 14, UK Russia 6.
- **Removed since listing:** 16 US listings made since 2024 in the tracked countries were later removed (Türkiye 12, India 4). They are not in `measures.csv`, which holds measures in force; they are in `data/clean/removals.csv`.

## How each list was read

- **US.** OFAC SDN List, advanced XML, issued 5 October 2026, with OFAC's action pages to 5 October 2026.
  - Only the SDN List entry of each party is used for its date and tags. A party's older SSI or Consolidated List entry would otherwise date it earlier (Gazprombank's SDN entry is dated 21 November 2024; its SSI entry 2014).
  - Programme: the tags OFAC printed on the action page on the day of listing. Russia: RUSSIA-EO14024, RUSSIA-EO14065, UKRAINE-EO13660/13661/13662/13685, CAATSA - RUSSIA, PEESA-EO14039, SSIDES, BPI-RUSSIA-EO14024. Iran: IRAN, IRAN-EO13846/13871/13876/13902, IRAN-HR, IRAN-TRA, IRAN-CON-ARMS-EO, IRGC, IFSR, HRIT-IR, CAATSA - IRAN, IFCA, ISA. CAATSA Titles I and II count as Iran and Russia; MAGNIT (OFAC programme "Magnitsky") does not.
  - Tags added later: a scan of the "changes" sections of every action page since 2024 finds three entries in the tracked countries that gained a Russia or Iran tag: Enka Trading (Hong Kong, Iran tags added 9 July 2025; listed under Russia on 12 June 2024), Chang Guang Satellite Technology (China, Iran tag added 8 May 2026) and VTB Bank (India and China addresses, Iran tag added 14 September 2026). Each is a separate "programme added" record.
  - Names: people as OFAC prints them, "SURNAME, Given Middle", built from the name-part types in the XML.
  - Every record was matched to the OFAC Recent Actions page of its date: all 1,159 found (six under OFAC's own spelling, rename or a.k.a., recorded in check_status).
  - Press releases: every Treasury and State Department release linked from an action page was saved (372: 325 Treasury, 47 State Department; the seven State pages that have moved were read from the State Department's archive site, 2021-2025.state.gov, on 7 October 2026). Releases issued the same day that an action page does not link were read as well: 28 (26 State Department, 2 Treasury), mostly State Department fact sheets for designations made alongside Treasury's, each found by one reader and checked by a second (`data/raw/ofac/press/same_day_releases.csv`, which also lists 2 State releases that the pages do link). A record carries a release only if the release names it. 45 targets that a release names in a form the script cannot match (a short name in a list, or another spelling such as "Cherry Star" for "Chery Star") were matched by one reader and confirmed by a second, and the build checks each quote against the saved release; for 3 targets a reader chose the reason sentence because the first sentence naming them is about another designee or a parallel designation (`name_matches.csv`). `reason_given` quotes the release sentence that names the target (1,107 records); a bare entry in a list is not quoted, and 7 records have no release at all. 285 US records are shown as State Department designations: a State Department release names them and no Treasury release does.
- **UK.** UK Sanctions List XML, report date 6 October 2026. Regimes: The Russia (Sanctions) (EU Exit) Regulations 2019; The Iran (Sanctions) Regulations 2023; The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. Where the list leaves the address country blank, the country is read from the address lines (BX Energy and Nord Axis Ltd, both Hong Kong).
- **EU asset freezes.** EU consolidated financial sanctions file, generated 22 September 2026 (a fresh download on 6 October was identical).
  - The file lacks whole acts. `scripts/check_eu_coverage.py` compares it with every "Addition" to a listing annex since 2024 in the EUR-Lex amendment lists of Regulations 269/2014, 2024/1485, 2024/2642, 267/2012, 359/2011 and 2023/1529: 10 acts of March–August 2026 are missing and 3 came after the file. All 13 were read on EUR-Lex; one, Implementing Regulation 2026/1361 of 15 June 2026, lists 12 firms in the tracked countries (records `EU-ACT-2026-1361-…`). EUR-Lex was unavailable on 6 October (HTTP 503 and 504), so the check for newer acts used the EU Publications Office's official record of CFSP acts (its SPARQL service): no Russia or Iran listing act was published between 29 September and 5 October 2026 (`data/raw/eu/cellar_cfsp_acts_since_2026-09-15_read_2026-10-06.csv`). Two corrigenda to Russia acts were published in that period, to Regulation 2025/395 (which added Annex IV entries) and Implementing Regulation 2023/429; they correct only the Slovenian and French versions, so the English text used here is unchanged (`data/raw/eu/cellar_corrigenda_languages_read_2026-10-06.csv`).
  - Every EU record is matched to its row in the listing act (`scripts/parse_eu_acts.py`, 23 acts, 984 rows; the row counts match each act's own recital wherever the recital gives numbers). The record takes the act's name for the target, the act's address order, and the Implementing Regulation that added it. The EU file sometimes cites the CFSP Decision instead (2026/1845 for 2026/1843); the record notes this.
  - Four entities listed on 20 May 2025 have no designation date in the EU file; the date of the listing act is used.
  - Eight Iran listings dated 29 September 2025 are re-impositions: the act's date cell gives the first listing and "suspended since 16.1.2016". They are coded `listing (re-imposed)`, with Regulation 267/2012 as the legal basis.
- **EU Annex IV.** Annex IV of Regulation 833/2014 from the EUR-Lex consolidated text of 24 July 2026. Each record links to the amending act that added it. Dates carrying a corrigendum marker ("►C15 24.4.2026 ◄") are now read (27 entries of 24 April 2026 had been missed). Country names, Indian cities and states, emirates and Turkish provinces are recognised, so a New Delhi address with no "India" counts (Agrim Aviation).

## Country coding

- **Hong Kong** (`scripts/hk.py`). All three lists often file Hong Kong addresses under China. An address is coded HK when it names Hong Kong or one of 77 Hong Kong districts, areas and streets listed in the script (Wyndham Street, Harcourt Road and others). A mainland address is never coded HK: names such as "Qianhai Shenzhen-Hong Kong Cooperation Zone" or Qingdao's "Hong Kong Middle Road" are ignored, and an address naming a mainland city or province needs a Hong Kong district, not just the words "Hong Kong". Street names that also exist elsewhere (Admiralty, North Point, Gloucester Road) count only on addresses the authority filed under China.
- **Fixed by the review:** JST Group (US) is Hong Kong (16 Wyndham Street); Shenzhen A Technology (US) and Shenzhen Blue Hat (UK) are mainland China.
- **Two or more tracked countries:** counted under the first address the authority lists (EU: in the act), with the others in `also_in_tracked`.
- **The same firm under China by one authority and Hong Kong by another** happens when the authorities list different addresses (ACE Electronic HK, Hong Kong Qisu, M Star). The China and Hong Kong page shows both together.
- **Address precision:** street 1,300; city 176; country only 194 (UK and US listings that give only "United Arab Emirates", "China" or another country); registration only 4. A street, building or unit counts as street; a postcode or PO box with a city counts as city.
- `also_listed_by`: 194 records name a target that another authority also lists under the same name. It is a name match, not a legal finding.

## What is left out, and why

- **Other US programmes.** 291 recent US listings in the tracked countries carry only other tags (counter-terrorism SDGT, non-proliferation NPWMD, cyber and others) and are left out by rule 1. Some concern Iran: OFAC's own data link 46 of them to an Iran-tagged party or mark them "Subject to Secondary Sanctions", and in 15 the Treasury sentence about the target mentions Iran or the IRGC. OFAC's tags follow the legal route of each designation, so one Treasury action can produce both counted and left-out listings. All 291 are in the workbook's "Left out" tab with OFAC's links and the Treasury sentence. OFAC added Iran tags to HIZBALLAH on 20 August 2026; links to it before that date are not treated as Iran links.
- **Vessels and aircraft** (OFAC party type Transport; UK "Ship"): not located in a country. The firms that own or manage them are in, where listed.
- **People with no address** in a tracked country (for example EU listings of people given only by nationality).

## Checks

- **Independent verification of every change (6 October):** independent checkers re-checked all 53 new records, every record whose name, country, date, programme or source changed, a sample of re-ordered US names, 24 quoted press-release sentences and all 16 removals against the live official pages, with a second checker re-examining each flag. 20 errors were confirmed and fixed: EU dates where the EU file gives the publication date instead of the act's date of listing (5), address precision (10), two press sentences cut at an abbreviation, two Hong Kong notes on records coded China, and one legal basis (Enka Trading). Each fix is general (in the scripts), so it applies to every record, not only those checked.

- **Second check of every record:** 1,674 of 1,674 passed.
  - US: the name on the OFAC action page of the listing date (script).
  - EU: name, a tracked country and the date of listing in the row of the act, fetched again from EUR-Lex (script).
  - UK: ID, name, date, regime and country in the UK HTML export, a second official format (script).
- **30-record check against the live official pages:** 30 of 30 passed (Day 1).
- **Separate reviews:** programme coding, the country coding of every record, completeness against the official files, and every trade figure. Their findings are fixed above. Reviews and checks are reproducible from the scripts and the saved official files.

## Known limits of version one

1. **Removals.** Only US removals are logged. EU deletions and UK delistings of entries made since 2024 are not yet logged.
2. **Other US lists.** The Commerce Department's Entity List and OFAC's non-SDN lists are not in version one.
3. **Sector.** Not yet coded. The plan codes it weekly.
4. **EU file lag.** The EU file lacked 13 acts; the coverage check must run every week.
5. **Rules records** (tariffs, sector rules, bank warnings) are in `data/clean/rules.csv`, checked separately.

## Trade at stake (UN Comtrade, read 6 October 2026)

US$ billion, goods, HS total. Figures behind the notes are in `data/clean/trade_notes.csv`.

| Country | Year | Exports to world | To US | To EU-27 | To UK | Exports to Russia | Imports from Russia | Exports to Iran | Imports from Iran |
|---|---|---|---|---|---|---|---|---|---|
| India | 2025 | 445.8 | 92.6 | 73.7 | 13.8 | 4.5 | 62.9 | 1.2 | 0.9 |
| UAE (own report) | 2023 | 570.2 | 13.5 | 16.0 | 2.9 | 4.5 | 6.4 | 5.8 | 0.5 |
| UAE (mirror) | 2025 | – | 7.9 | 11.2 | 3.0 | – | – | – | – |
| Türkiye | 2025 | 273.4 | 16.3 | 119.5 | 16.8 | 6.7 | 42.4 | 3.1 | 2.5 |
| China | 2025 | 3,776.4 | 421.0 | 560.8 | 85.2 | 103.5 | 124.0 | 6.9 | 3.0 |
| Hong Kong | 2025 | 754.4 | 45.9 | 35.1 | 10.8 | 1.6 | 13.1 | <0.1 | <0.1 |

- **The UAE** has not reported 2024 or 2025 to UN Comtrade. Its own 2023 exports include re-exports (US$167.0bn of US$570.2bn; US$4.2bn of US$4.5bn to Russia and US$5.3bn of US$5.8bn to Iran) and are valued f.o.b. The 2025 row is mirror data (imports from the UAE recorded by the US, the EU-27 and the UK, valued c.i.f.); the two rows are not comparable. For comparison, 2023 mirror figures: US 6.9, EU-27 18.3, UK 3.0.
- **Hong Kong's** figures include re-exports and gold: US$80.4bn of its 2025 exports were gold (HS 7108), and of its US$13.1bn imports from Russia, US$10.5bn were gold, US$1.5bn platinum-group metals and US$0.3bn silver.
- **Hong Kong and Iran:** exports US$27.5 million, imports US$3.1 million.
- **The EU-27** is the sum of the 27 members' figures. All 27 are present for every country.

## Corrections

Write to editor@geopoliticaleconomist.com with the record ID and your source. Errors are corrected within two working days and logged in `data/clean/corrections.csv` and on the method page.