Documentation · Data model

Sanctions programmes

Sanctions are imposed under programmes: a legal regime with its own scope, targets and measures. A source tells you who published a listing; a programme tells you why and under which law.

Programmes and sources

A programme is the regime or list name a publisher attaches to a listing: a country schedule under Canada’s Special Economic Measures Act, an OFAC programme tag, a United Nations committee list. One source can carry many programmes. Canada’s consolidated autonomous sanctions list, for example, brings together the regulations made for each country under that Act and listings under the Justice for Victims of Corrupt Foreign Officials Act. The same programme can also appear in several sources when publishers copy each other, as when national lists reproduce United Nations designations.

Browse the programmes in our data in the programme directory; each has its own page with the parties designated under it.

The same list is published as a file, /downloads/meta/programmes.json: one entry per sanctions programme with its record count, the registers that use it, counts of people, organizations and vessels, and when it was first and last seen. Its generated_at field says when it was written; /api/programs gives the live figures.

Other things the field holds

Publishers do not all use the programme field the same way. Some put a sub-list, a decision reference or even the type of party there: the Monaco list gives “Personne physique” (natural person), and the French register gives the UN committee decision and its date. We keep the publisher’s wording and do not reinterpret it. Rows that hold our own loading notes are left out of the directory and the downloads.

How programmes appear in the data

The programme is the program property of the Sanction entity, next to the register that published it:

{
  "id": "crown-379597165-sanction",
  "schema": "Sanction",
  "caption": "RUSSIA-EO14024",
  "properties": {
    "entity": [
      "crown-379597165"
    ],
    "authority": [
      "OFAC SDN"
    ],
    "program": [
      "RUSSIA-EO14024"
    ]
  },
  "datasets": [
    "ofac_sdn"
  ],
  "first_seen": "2026-09-24T11:20:04.023474+00:00",
  "last_seen": "2026-09-24T11:20:04.023474+00:00",
  "last_change": "2026-09-24T11:20:04.023474+00:00"
}

FollowTheMoney also defines programId (a stable programme key) and programUrl (the official page). We reserve both, and the program_ids column of the simplified CSV, until a programme catalogue exists. The programme directory is also available as JSON from /api/programs; see the endpoint reference.

What we know about each programme

Field	Held today?	Notes
Name as published	Yes	Exactly as the publisher wrote it.
Records designated under it	Yes	Counted live on each programme page, split by people, organizations and vessels.
Sources that use it	Yes	With the country of each publishing source.
Last updated	Yes	The most recent load of any record under it.
Stable key	Not yet	Needs the catalogue.
Official title and summary	Not yet	Needs the catalogue.
Issuing authority and country	Not yet	Today we show the country of the source, which differs when a list copies another authority’s programme.
Legal basis and official link	Not yet	Needs the catalogue.
Targeted countries	Not yet	Needs the catalogue.
Measures (asset freeze, travel ban, arms embargo…)	Not yet	Needs the catalogue and a vocabulary of measures.

Planned work. A programme catalogue with code, name, issuing authority, country, legal basis, official link and linked lists, built from official issuers (OFAC, the EU, UK OFSI, the UN, Canada, Switzerland, Australia, Japan and others), with free-text programme values mapped onto it (data backlog item 7), and removal of loading notes from programme text (item 21).

Sanctions measures

Programmes impose different measures: freezing assets, banning travel, prohibiting dealings, restricting trade in arms or other goods, or barring access to services. In Canada, for example, regulations under the Special Economic Measures Act commonly prohibit dealings in a listed person’s property and can make a listed individual inadmissible to Canada.

To be provided: the scope of the programme catalogue and a vocabulary of measures with our own definitions (trade and goods, financial, services and access, sectoral), including how borderline cases are classified. Needs an owner decision on whether and when to build the catalogue.

Last updated 2026-10-04