How the Third-Country Sanctions Monitor Is Built and Checked

Scope

What counts as a record?

• One record is one measure by the US, the EU or the UK against one firm or person with an address in India, the UAE, Türkiye, mainland China or Hong Kong. A third country is any country other than Russia, Iran and the one imposing the measure.

• Only measures under the Russia and Iran sanctions programmes count, as the authority itself tags them: OFAC programme tags, the UK sanctions regime, the EU regulation. A US listing under another programme, for example counter-terrorism, is left out even when the press release mentions Iran. Those listings are shown, with OFAC’s own links, in the workbook’s “Left out” tab.

  Workbook, Left out tab (Excel)

• Window: measures dated 1 January 2024 or later. The current version holds 1,674 records: 1,159 US, 242 EU and 273 UK.

• Types of measure: listing (an asset freeze or blocking), re-imposed listing (8 EU listings restored on 29 September 2025 after being suspended under the 2015 nuclear deal), export control (157 EU Annex IV entries), and programme added (3 US entries that gained Iran tags after they were first listed).

  All measures (CSV)

• Where the authority gives no address, a place of registration, company number or principal place of business that it states counts, and the record says so.

• Vessels and aircraft are left out: they are not located in a country. The firms that own or manage them are in, where they are listed.

• Records are measures in force on the list dates. 16 US listings made since 2024 in the four countries and later removed are kept in a separate file.

  Listings removed since 2024 (CSV)

Sources

Where does the data come from, and which version?

Coding

How is each record coded?

• Names are as the authority writes them. US individuals appear as OFAC prints them (SURNAME, Given names); EU names are taken from the listing act. Pages name firms and count people; the official entries for people are in the download. Three firms’ official names contain the name of a listed person, one in a different spelling; the pages show them by the short names Treasury uses: Skies Petroleum, VGGW and MRPCG Trading.

  All measures (CSV) · Workbook, Fields tab (Excel)

• Country is the tracked country of the first address the authority lists (for EU listings, in the order of the listing act). Other tracked countries are shown as also present.

• Hong Kong: all three lists often file Hong Kong addresses under China. An address is shown as Hong Kong when it names Hong Kong or a Hong Kong district or street. A mainland address is never shown as Hong Kong, even when a place name contains the words (Shenzhen’s Qianhai Shenzhen-Hong Kong Cooperation Zone, Qingdao’s Hong Kong Middle Road).

• US programme: the tags OFAC printed on the day of listing. Russia tags: RUSSIA-EO14024, RUSSIA-EO14065, UKRAINE-EO13660, 13661, 13662 and 13685, CAATSA - RUSSIA, PEESA-EO14039, SSIDES and BPI-RUSSIA-EO14024. Iran tags: IRAN and the IRAN-EO tags, IRAN-HR, IRAN-TRA, IRAN-CON-ARMS-EO, IRGC, IFSR, HRIT-IR, CAATSA - IRAN, IFCA and ISA.

• US acting body: OFAC keeps the SDN List, but some listings are State Department designations. A US listing that only a State Department release names is shown as a State Department designation. The State Department’s own releases of the same day are read as well, because OFAC’s action pages often do not link them.

• US reasons: the sentence of the Treasury or State Department press release that names the target, quoted as written, where one does. UK reasons: the UK statement of reasons. EU: the identifying information or the reasons in the act.

• The same firm can appear under China for one authority and Hong Kong for another when they list different addresses; the China and Hong Kong page shows both.

Checks

How was every record checked?

• Every record was checked a second time against an official source: 1,674 of 1,674 passed. US: the name on the OFAC action page of the listing date. EU: name, country and date in the row of the listing act on EUR-Lex. UK: ID, name, date, regime and country in the UK’s HTML export, a second official format.

  Workbook with checks: Second checks and Check log tabs (Excel)

• A random sample of 30 records was also checked against the live official pages: the US and EU records by a script that fetched each page, and the UK records on the UK Sanctions List service in a browser. All passed.

• Separate reviews checked the programme coding, the country coding of every record, whether any listing was missed, and every trade figure, and each finding was checked a second time. The findings were fixed before publication, and every new or changed record was checked again against the live official pages.

• The EU’s consolidated list is compared every week with the EUR-Lex record of every listing act; acts it lacks are read from EUR-Lex directly. The file of 22 September 2026 lacked 13 listing acts: ten Council implementing regulations adopted between March and August 2026 (2026/613, 885, 1356, 1361, 1362, 1708, 1710, 1851, 1883 and 1940) and three adopted after the file was generated (2026/2165, 2184 and 2193).

  2026/613 · 2026/885 · 2026/1356 · 2026/1361 · 2026/1362 · 2026/1708 · 2026/1710 · 2026/1851 · 2026/1883 · 2026/1940 · 2026/2165 · 2026/2184 · 2026/2193

Limits

What does version one leave out?

• Removals: only US removals are logged so far. EU deletions and UK delistings of entries made since 2024 are not yet logged.

  Listings removed since 2024 (CSV)

• Other lists: the US Commerce Department’s Entity List and OFAC’s non-SDN lists are not in version one.

• Sector: not yet coded for each record; the reasons field gives the authority’s own description.

• Countries: four pilot pages (India, the UAE, Türkiye, and China with Hong Kong). More countries follow from November 2026.

• Trade figures are goods only, from each country’s own report to UN Comtrade. The UAE has not reported 2024 or 2025; its 2025 row is mirror data and is not comparable with its own 2023 report.

  UN Comtrade · Trade at stake (CSV)

Corrections

Corrections

If a record is wrong, write to the editor ([email protected]) with the record ID and your source. Errors are corrected within two working days, and every correction is logged here with the date, what changed and the source.

1. 8 October 2026

   US-OFAC-54047. Was: the reason sentence included the titles of two linked Treasury pages. Now: it reads as in the release, ending “such as JAM PETROCHEMICAL COMPANY, TABRIZ PETROCHEMICAL COMPANY and PERSIAN GULF PETROCHEMICAL INDUSTRY COMMERCIAL CO”. Same cause. No other field changed. Source

2. 8 October 2026

   US-OFAC-54046. Was: the reason sentence ended with the title of a linked Treasury page (“Treasury Sanctions Companies Selling, Purchasing, and Enabling Iranian Petrochemical Products | U.S. Department of the Treasury”). Now: the sentence ends at “to third party countries”, as in the release. The release prints the titles of linked pages inside its sentences; they are link labels, not part of the reason. No other field changed. Source

Use

Not legal advice

• This monitor records official actions published by the US, the EU and the UK. A listing is a decision of the authority named; it is not a finding by The Geopolitical Economist, and the monitor does not say that any firm or person broke any law.

• It is not legal advice and not a screening tool. Before acting, check the authority’s own list: OFAC’s Sanctions List Search, the UK Sanctions List and the EU Sanctions Map or EUR-Lex.

  OFAC Sanctions List Search · UK Sanctions List · EU Sanctions Map · EUR-Lex

• Firms and people can be removed from a list. The monitor shows the status on the list dates given above.