Multi-Jurisdiction Sanctions Cross-Reference Discovery

Date: 2026-04-20 Method: Ingested EU FSF (5,782 entries), UK FCDO (5,999), Ukraine NSDC (21,295) consolidated sanction lists from OpenSanctions. Matched against our existing Organization graph by Russian INN.

Headline

• 33,076 external sanction entries ingested as :SanctionedEntity nodes
• 15,678 INN-based links (ON_SANCTIONS_LIST edges) to Organizations already in the graph
• 2,776 Organizations newly cross-matched — orgs that are sanctioned by EU, UK, or UA but NOT previously flagged sanctioned=true in our graph (which tracks US OFAC SDN only)
• 903 SanctionedEntity records appear on 2+ jurisdiction lists

Coverage by list

Interpretation: Ukraine's NSDC list is by far the broadest (21k vs 6k for EU/UK) — Kyiv sanctions substantially more Russian entities than Western jurisdictions. Many of these are targets that Western sanctions have not yet reached.

2026-04-20 expansion: now 9 jurisdictions

Updated coverage: Added Canada SEMA (5,417), Australia DFAT (3,715), Japan MoF (2,808), Swiss SECO (6,458), New Zealand Russia (1,852). Total row count now 53,326 across 9 jurisdictions.

Cross-jurisdiction distribution (SanctionedEntity nodes by number of lists):

• 7 entities on 6 jurisdictions
• 72 on 5
• 345 on 4
• 1,292 on 3
• 3,749 on 2
• 39,469 on 1

Russian entities sanctioned by ALL 7 Western-aligned jurisdictions (EU+UK+UA+CA+AU+JP+CH+NZ)

New designation-gap findings (non-OFAC on ≥4 Western lists)

Совфрахт and Объединенная Приборостроительная Корпорация (ОПК) are now the two highest-leverage OFAC designation gaps — sanctioned by 5-6 allied jurisdictions but not by the United States.

Triple-list entities (NOT US-sanctioned, on EU + UK + UA)

These 7 Russian entities are sanctioned by every Western-aligned jurisdiction in our set EXCEPT the United States. Each is a primary candidate for an imminent OFAC designation to close the gap:

Occupied-territory cohort with multi-list matches

OT-prefix (91/92/93/94/95/9001) Organizations that are sanctioned by ≥1 Western/Ukrainian jurisdiction:

2-list OT targets

Policy signal: Crimea-shipbuilding sector is fully-sanctioned by EU/UA but only 1 of the 2 (Залив) is OFAC SDN; MORE (9108124167) is not.

1-list OT targets (Ukraine-only)

Most of the 2,751 Ukraine-only matches are OT-prefix entities Ukraine has sanctioned as part of its blanket "anti-occupation" decrees. Notable:

Distribution of jurisdictional overlap

Recommended follow-on actions

1. Designation briefs for the 7 triple-list targets — these are the highest-leverage OFAC designation candidates. Совфрахт and РН-Аэро alone close massive logistics/fuel gaps.
2. Propagate sanctioned=true flag to Organizations matched by ≥1 external list, or add a separate externally_sanctioned_count property — this affects existing graph queries that rely on the sanctioned flag. Currently only US-OFAC toggles it.
3. Run secondary-sanctions adjacency (CAATSA §231 / 50% Rule) with the expanded "sanctioned" universe — finds US-facing entities transacting with EU/UK/UA-only-sanctioned Russian targets.
4. Refresh periodically — fetch_multi_sanctions.py + ingest_multi_sanctions is now wired into run_pipeline.py and run_all.py MODULE_ORDER. Will update on each periodic run.

Artifacts

• Fetch script: pipeline/fetch_multi_sanctions.py (OPTIONAL_STEPS)
• Ingest module: pipeline/neo4j_ingest/ingest_multi_sanctions.py (MODULE_ORDER, position after sanctions)
• Raw data: pipeline/data/multi_sanctions/{eu_fsf, gb_fcdo_sanctions, ua_nsdc_sanctions, gb_hmt_invbans}_targets.csv
• Fetch metadata: pipeline/data/multi_sanctions/fetch_meta.json
• Graph nodes/edges: :SanctionedEntity (33,076 rows) + :ON_SANCTIONS_LIST edges (15,678)