Europe Regional Sanctions Guide

Global Sanctions Index: Main

Out of Europe’s 49 countries, 12 have autonomous sanctions lists, and the 27 European Union (EU) members also follow EU sanctions. Across the continent, the quality of sanctions lists vary widely, with some providing detailed and clean data schemes and others falling short in all three index categories of data integrity, data delivery, and guidance. The highest rated autonomous sanctions list was France’s Tresor Registre Des Gels while the lowest rated sanctions list was Russia’s Rosfinmonitoring List of Terrorists and Extremists. 

The Variety of European Lists

The countries with autonomous sanctions lists in Europe are Armenia, Azerbaijan, Belgium, France, the Holy See, Latvia, the Netherlands, Poland, Russia, Switzerland, the United Kingdom, and Ukraine. Out of the 12 autonomous sanctions lists, France’s Tresor Registre Des Gels scored the highest rating with 90%. 

As the highest quality autonomous sanctions list in Europe, France’s Tresor Registre Des Gels scored a perfect rating under the guidance category. It includes a public guide for users wishing to explore the Tresor Registre Des Gels’ sanctions data, helping them navigate the expansive data and technical language found within the watchlist. The French list also includes detailed explanations regarding why a subject is listed for each entry, which allows users to fully comprehend the reasoning behind each entry. The Tresor Registre Des Gels also has a well-organized and elaborate collection of data. ID fields are limited to one entry per field (in comparison to Russia’s Rosfinmonitoring list where multiple entries are crammed into one ID field), and data input is standardized in comparison to the manual entries seen in the Holy See’s autonomous sanctions list. Although the Tresor Registre Des Gels falters when regarding search tool functionality as there are no easy to use filters, France’s list rated highly on account of overall comprehensibility.

Switzerland SECO’s sanctions have the second best score in Europe with the rating of 85%, which reflects the inclusion of detailed explanations for entries and an easy to use watchlist search tool. Like France’s list, each entry in Switzerland SECO’s list has an accompanying justification which aids users' understanding of why a particular subject is sanctioned (this is in contrast to US OFAC SDN sanctions, where entries do not have linked explanations for why they are sanctioned). Switzerland SECO also excels when it comes to user accommodation, as the list includes a straightforward watchlist search tool that delivers understandable results. Despite ranking highly in guidance, Switzerland’s list lacked when it came to data accessibility, as the watchlist cannot be downloaded in multiple formats, only allowing for XML and CSV formats and lacking PDF. 

With a score of 53%, the Netherlands Terrorist Sanctions list and Armenia’s Domestic List of Designated Persons tied for the second lowest ratings among European sanctions lists. The Netherlands Terrorist Sanctions list performed most poorly in the category of data delivery, given that there is no watchlist search tool and no email notifications. The Netherlands’ list also does not provide publicly available guidance for users exploring the watchlist, and explanations for entries are not included on the actual watchlist. Instead, users must go to a separate link in order to read explanations regarding why subjects are sanctioned. Armenia’s list had nearly identical issues across Data Integrity, Data Delivery, and Guidance categories.

The lowest performing autonomous sanctions lists of Europe was Russia’s Rosfinmonitoring List of Terrorists and Extremists. As the lowest ranked list in Europe with a score of 51%, the Russian list lacks the basic tools that are necessary in order to form an accessible and functioning national sanctions source. Russia’s list does not include a comprehensive data schema, since data input is often not standardized and oftentimes ID fields have multiple entries within a single field. The Rosfinmonitoring list excludes unique identifiers and location information for each entry, which increases the chance of encountering false positive results. Russia’s Rosfinmonitoring List of Terrorists and Extremists is also difficult to access from non-Russian IP addresses, which further lowers the list’s rating.  

The EU Consolidated List

The European Union maintains a consolidated list of “persons, groups, and entities” who are subject to EU sanctions. All 27 EU member states must decide upon and implement EU sanctions against non-EU countries in order to prevent conflict, defend international law and security, or promote peace. The European Commission monitors the implementation of EU sanctions across the member states. Many EU member states such as Finland and Denmark only mandate that companies follow the EU’s EU consolidated sanctions list and do not employ a national sanctions list.

The European Union’s sanctions list scored an impressive 88% due to its data integrity, data delivery, and guidance to users. The EU sanctions list has detailed and comprehensive data, which is reflected by the inclusion of unique identifiers for all entries and the precise record of subjects’ locations. The EU also achieved perfect scores within the guidance category, which reflects the inclusion of detailed explanations as to why entries are listed. The EU website also offers helpful guidance for users exploring the EU sanctions list or the watchlist search tool–the EU sanctions map. However, the EU sanctions map tool scored poorly for usability, as there are limited filters that would allow users to search based on criteria like: individuals sanctioned in Russia.

Although the EU consolidated list scored high as a result of its detailed data schema and ontology and easy to understand presentation, it complicates access by requiring all users to create an account before accessing consolidated sanctions files.

Holy See Has a Sanctions List, but Italy Doesn’t?

Notably, the Holy See (i.e. the Vatican) utilizes an autonomous sanctions list while Italy does not. Italy, which is both a United Nations and European Union member, implements UN and EU sanctions in lieu of a national sanctions list. The Holy See, which does not belong to the UN or EU, conversely utilizes an autonomous sanctions list that is primarily targeting terrorist financing. Despite The Holy See’s national sanctions list scoring a 59.3%, or the third lowest ranking in Europe, the list holds value as a frequently-updated public tool which lists subjects that “threaten international peace and security.”

What About the Other 38 Countries in Europe? 

The overwhelming majority of countries globally do not have autonomous 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, Bulgaria, Germany and Italy do not have a national sanctions list, but they impose sanctions levied by the European Union and actively partake in the EU’s sanctions process. Therefore, while some countries in Europe, such as France and Netherlands, choose to publish autonomous national sanctions lists in order to support national security, the majority of European countries solely implement EU and 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, and 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.