Documentation · Data model
Risk topics
Every party in our data carries a topic that says, in one code, why it is there. Topics let you filter, route alerts and weigh matches without reading each listing.
Topics we assign
Topic codes come from the FollowTheMoney topic list, so they mean the same thing in our files as in other tools that use the model.
| Topic | Meaning | Assigned when |
|---|---|---|
sanction | Subject to sanctions: asset freezes, travel bans, trade restrictions or a terrorist designation. | The record comes from a register of list type SANCTION, or its list type is unknown. |
role.pep | Politically exposed person: holds or held a prominent public function. | The record comes from a register of list type PEP. |
debarment | Excluded from public contracts, government programmes or a regulated profession. | The record comes from a register of list type DEBARMENT. |
reg.action | Subject of a regulatory or enforcement action. | The record comes from a register of list type TAX_WARRANT or INSOLVENCY. |
Topics are in the topics property of each entity and in the topics field of API records. Each record has exactly one topic today, taken from its register’s list type. A person on a sanctions list and a PEP register has two records, one with each topic.
What to keep in mind
- The topic describes the register, not a finding about the person. Check the listing itself before acting.
- A few registers are filed under the wrong list type, so their records carry the wrong topic: for example court decisions filed under sanctions. Fixing this is data backlog item 33.
reg.actionis broad. It covers tax warrants and insolvency notices, which many screening programmes treat very differently from sanctions.
Topics we do not assign yet
FollowTheMoney defines finer topics that we cannot yet derive reliably. None of the following appear in our data:
| Topic | Meaning |
|---|---|
sanction.linked | Linked to a sanctioned party, for example owned or controlled by one. |
sanction.counter | Named on a counter-sanctions list issued against other countries’ officials. |
role.rca | Relative or close associate of a politically exposed person. |
poi | Person of interest, without a formal listing. |
crime | Linked to crime, for example convicted or charged. |
wanted | Sought by law enforcement. |
export.control | Subject to export controls. |
reg.warn | Subject of a regulator’s public warning. |
sanction.linked and role.rca (item 23).Politically exposed persons
FollowTheMoney also has topics for the kind of public position a PEP holds, such as national government, legislature, judiciary or diplomatic roles. We do not assign them yet: the role of each PEP is kept as the publisher’s free text in the program field, and mapping those descriptions onto a fixed set of roles is planned (data backlog item 11). See the PEP collection and PEP coverage.
Last updated 2026-10-04