Policy for sanctions lists that mimic international programs

Our sanctions data philosophy

At Comply, we believe that effective compliance requires both quality and completeness. That’s why we go beyond simply collecting large volumes of data — we prioritize accurate, relevant, and well-sourced information that reflects how sanctions are enforced in the real world. Our research team monitors official sources daily to ensure our coverage is not only up to date but also meaningful and actionable.

As part of this commitment, we've reviewed a number of national sanctions sources that do not publish their own autonomous designations. Instead, these sources directly replicate international or foreign sanctions lists — such as those issued by the UN, EU, or other governments — without adding any new entries. Because they don’t introduce unique data, we've marked these lists as “suspended” in our platform.

This does not affect your compliance coverage. To remain fully aligned with regulatory expectations, we recommend continuing to screen against the underlying international programs referenced by these sources.

Ongoing monitoring of suspended sanctions sources that mimic international programs

Although sanctions lists that mirror international programs are currently suspended, we maintain a proactive monitoring process to identify any signs of reactivation or the emergence of independent national sanctions regimes. We do this through multiple channels:

• Ongoing automated monitoring: Through automated tools, we are actively monitoring official sources for any indication that a country may have begun issuing domestic sanctions independently. This includes reviewing the official source, and a range of legal instruments — such as ministerial ordinances, executive decrees, or special government announcements — that may fall outside the main sanctions publications but can still signal the introduction of new domestic measures. If our monitoring systems detect potential national designations, they are promptly integrated into our screening processes.

• News and authority monitoring: We actively track developments from sanctions authorities through tools such as Google News feeds, RSS subscriptions, and automated email alerts, where available. This approach helps us identify announcements that may not appear in primary sanctions publications, especially when domestic measures are released through alternative channels. By maintaining comprehensive news and authority monitoring, we stay ahead of changes, reinstatements, or the launch of new sanctions programs, ensuring our data remains timely, complete, and accurate.

List of sanction sources being suspended:

Liechtenstein

Liechtenstein does not maintain an autonomous national sanctions list. Instead, due to its customs and currency union with Switzerland, it adopts Swiss sanctions. These already incorporate designations from both the United Nations (UN) and the European Union (EU).

Local regulations are published in the Liechtenstein Gazette to make these external sanctions binding domestically, but Liechtenstein itself does not make any additional designations.

If your compliance processes already screen against UN, EU, and Swiss sanctions, you are fully aligned with Liechtenstein's legal requirements.

Lists that should be screened for full compliance:

• United Nations Consolidated List.

• European Union Council Restrictive Measures.

• EU External Action Service – Consolidated List of Sanctions.

• Switzerland SECO Sanctions List.

Suspended list: Liechtenstein International Sanctions (Suspended)

Iceland

Iceland is not an EU member, but as part of the European Economic Area (EEA), it integrates EU sanctions and all binding UN Security Council resolutions into its domestic legal system.

Iceland does not publish its own list of sanctioned individuals or entities. Instead, it references EU and UN measures in national legislation.

If you already screen against both UN and EU lists, you are meeting Icelandic compliance expectations.

Lists that should be screened for full compliance:

• United Nations Consolidated List.

• European Union Council Restrictive Measures.

• EU External Action Service – Consolidated List of Sanctions.

Suspended list: Iceland Sanctions List (Suspended)

Norway

Norway directly adopts UN sanctions and aligns with most EU restrictive measures via national law. Although Norwegian legislation allows for the possibility of autonomous national sanctions, no Norway-specific designations have been issued to date.

Norway does not maintain a standalone national sanctions list and instead references the UN and EU designations within its legal framework.

Screening against UN and EU lists is sufficient for full compliance with Norwegian sanctions law.

Lists that should be screened for full compliance:

• United Nations Consolidated List.

• European Union Council Restrictive Measures.

• EU External Action Service – Consolidated List of Sanctions.

Suspended list: Norway Sanctions and Restrictive Measures (Suspended)

South Africa

South Africa implements UN Security Council sanctions through its Financial Intelligence Centre (FIC). The FIC’s published sanctions lists — the Targeted Financial Sanctions (TFS) lists — are exact replicas of the UN Consolidated List. No additional or autonomous names are included.

The FIC itself clarifies that this is not a domestic list, but a reproduction of the UN designations.

If you are screening against the UN Consolidated List, your compliance processes fully align with South African requirements.

Lists that should be screened for full compliance:

• United Nations Consolidated List.

Suspended lists:

• South Africa Targeted Financial Sanctions List – Organisations (Suspended)

• South Africa Targeted Financial Sanctions List – Persons (Suspended)

Mexico

Mexico enforces UN sanctions through the Financial Intelligence Unit (UIF), which publishes Annexes A, B, and C related to terrorism financing and non-proliferation. These annexes are fully derived from the UN Consolidated List and contain no additional designations created by Mexican authorities.

If your screening already covers the UN Consolidated List, you are effectively meeting Mexican regulatory obligations.

Lists that should be screened for full compliance:

• United Nations Consolidated List.

Suspended list: Mexico Financial Intelligence Unit – UN Sanctions for Terrorism and Non-Proliferation (Suspended)