APAC & Oceania Regional Sanctions Guide

Global Sanctions Index: Main

The Asia Pacific region consists of 43 countries— 17 of which have autonomous sanctions lists. 40% of countries in APAC have autonomous sanctions lists, the highest percentage for any region globally. However, APAC also has the second-lowest average score for sanctions lists ratings with an average of 56%. With the exception of Australia and New Zealand’s lists, most autonomous sanctions lists in APAC lack a structured data schema and public guidance, resulting in sanctions data that is difficult to use and understand, and hindering regional compliance.

The Multitude of Asian Sanctions Lists

The APAC countries that utilize autonomous sanctions include: Australia, Bangladesh, China, India, Indonesia, Japan, Kazakhstan, Kyrgyzstan, Malaysia, Nepal, New Zealand, Pakistan, Singapore, South Korea, Tajikistan, Thailand, and Vietnam. The vast majority of these lists, such as the Central Bank of Bangladesh list (CBB) and Japan’s Ministry of Finance list (MOFA) have significant deficiencies and scored below 60%, due to the lack of an organized data schema and the lack of public accessibility, such as a watchlist search tool and email notifications. The widespread absence of public guidance and high quality data within the APAC sanctions sphere increases the difficulty of compliance and increases the rate of false positives and increases compliance costs. 

APAC: Quantity over Quality

With the exception of Australia and New Zealand, the autonomous sanctions lists belonging to APAC countries received poor scores. Only two sanctions lists, from Australia and New Zealand, scored in the “Best” category for ease of compliance. The majority of lists within the APAC region scored within the “Afterthought” range, meaning they are extremely challenging to use and in some cases actually hinder compliance.

Many of the countries scoring less than 59%, such as Vietnam and Singapore, have a small number of total sanctions designations. The small size of the APAC lists (China has less than a hundred entries) typically corresponds to an overall poor ranking. Smaller lists generally have a poorly structured data schema and lack public search tools and guidance that is common amongst larger sanctions lists.

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The Malaysian Ministry of Home Affairs (MHA) list scored the highest among Southeast and Eastern Asian lists with 68%. The Malaysian sanctions list performed well in data presentation and integrity because data input is standardized and the source uses a comprehensive schema with identifiers having their own fields (i.e. a passport is called a passport, not a generic “ID” and the passport number has its own field as opposed to being wedged into an “additional information field). The list additionally scored highly for accessibility by providing an easy-to-access database that does not require users to log in. Still, Malaysia MFA’s search platform does not allow viewers to filter by specific criteria and its lacks clear guidance for the public, limiting its overall utility.

Neighboring Indonesia’s List of Suspected Terrorists and Terrorist Organizations (DTTOT) scored 64%. Like the Malaysian MHA list, the DTTOT list includes standardized data input and a well-defined data schema with essential criteria having their own ID fields. There are also unique identifiers for each entry, which decreases the chance of encountering a false positive when searching sanctioned subjects. The Indonesian list falls short, however, when it comes to public accessibility and guidance. The DTTOT list is difficult to find from search engines and is not cross-referenced well on other Indonesian government websites, raising barriers to accessing compliance data. A watchlist search tool is also not included on the Indonesian Financial Transaction Reports and Analysis Centre website, limiting users’ ability to search for entries based on specific criteria.

The second-lowest regional score is for the Monetary Authority of Singapore’s (MAS) Terrorism Suppression of Financing Act sanctions, at 43%. Singapore’s autonomous sanctions scored well in data delivery, but the list scored low for data integrity and guidance for the public. The Monetary Authority of Singapore offers email notifications to users interested in sanctions updates, contributing to the watchlist’s accessibility, and the watchlist is also accessible without a login, strengthening data delivery. However there are no explanations regarding why an entry is listed, which makes it challenging to understand the reasoning behind a listing. 

China’s Ministry of Foreign Affairs (MFA) sanctions scored 21%, the lowest globally. The Chinese MFA publicizes new sanctions designations through press releases (which it then takes down), and does not maintain a consolidated list. The lack of a unified list with historical data makes it impossible to track Chinese sanctions without the use of a historical compliance database. China also rarely issues legal guidance about its designations, instead stating that parties are sanctioned for reasons such as “Severely harming China's sovereignty and interests and maliciously spreading lies and disinformation” making it  a constant gray area for compliance practitioners. China also has a history of issuing designations against the same targets multiple times. For example, China issued sanctions against US defense companies Lockheed Martin and Raytheon in February 2022, despite also sanctioning both companies in July 2020.  The difference between the two designations is unclear. ​​

Australia and New Zealand

Australia and New Zealand outperformed the rest of APAC due to high data integrity, data delivery and accessibility, and guidance. Both countries received a score of 80%, although for different reasons.

The Australian DFAT list has high quality data integrity and accessibility to the public. Each entry on the DFAT list has a unique identifier, which reduces the prevalence of false positives when screening the watchlist. The data is also organized in an orderly and efficient schema, with criteria such as citizenship and place of birth having their own fields. The Australian DFAT list is also accessible for the public. The watchlist is easy to find online and can be accessed without a login. Email notifications are also available for users interested in receiving sanctions updates from the Australian DFAT. The Australian list falters with the lack of a watchlist search tool and availability to download the sanctions watchlist in multiple formats. Another setback within the DFAT list is that explanations regarding why an entry is listed are not universal throughout the watchlist, which limits the lists overall usability. 

New Zealand’s Terrorist Sanctions list similarly excelled within the category of data integrity. The Terrorist Sanctions list includes standardized entries with detailed location information, which contributes to the list’s low false positive rate. The list also scored well within the guidance category because New Zealand provides an explanation justifying each designation. However, the New Zealand sanctions list is not as accessible as Australia's as it is challenging to find online and it does not provide update notifications. Finally, New Zealand does not provide a watchlist search tool, limiting the list’s functionality.

What About the Other 26 APAC Countries?  

The overwhelming majority of countries globally do not have sanctions programs. Instead, they rely on supranational organizations, primarily the United Nations and European Union, but also The Arab League and Economic Community of West African States (ECOWAS) to come up with sanctions, which they then adopt. For example, Cambodia, Sri Lanka, and Mongolia do not have a national sanctions list, but they implement sanctions issued by the United Nations. Though many countries in the APAC region do issue autonomous sanctions lists, these are often in support of their own national security policy and these countries also separately adhere to UN sanctions. Continued disagreement at the UN, however, means that few new sanctions are being imposed by countries that do not have their own sanctions programs, limiting their ability to respond to crises like Russia’s invasion of Ukraine, the military coup in Myanmar, or repression in Venezuela. 

About Castellum.AI

Castellum.AI obtains global sanctions information from primary sources, and then proceeds to standardize, clean and enrich the data, extracting key information like IDs and addresses from text blobs. Castellum.AI enriches as many as fifteen separate items per entry. This analysis is based on the enriched primary source data that populates our database. The database consists of over 1,000 watchlists, covering over 200 countries and eight different categories (sanctions, export control, law enforcement most wanted, contract debarment, politically exposed persons, regulatory enforcement, delisted, and elevated risk). Castellum.AI checks for watchlist updates every five minutes directly from issuing authorities.