Top Reasons for UK Sanctions

It’s pretty much what you would expect.

David Toy
jdtoy’s blog

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I’m researching the concept of ‘identity’ as defined by the UK’s Money Laundering Regulations, with an interest in bridging the online-offline gap.(Please get in touch if this area is also of interest to you.)

The JMLSG’s Guidance is the bible in this area. I’ve provided my identity documents to many financial organisations, but never truly appreciated how much goes on behind the scenes.

In addition to a bank knowing who you are, they must also ensure that you haven’t died already, and that you’re not on the ‘naughty list’. Or more officially, that you are not a “Person firms should not accept as customers”, as defined by HM Treasury’s list of sanctions.

I was pleasantly surprised that the list is public. (open data, ftw!) My curiosity piqued, I had a read through. The list includes as much information as is known about individuals and their aliases (often incomplete), and why HM Treasury has sanctioned them.

The UK’s Top Ten Naughty Regimes

Data valid: 24/10/16. 8760 names including aliases.

  1. The ISIL (Da’esh) and Al-Qaida organisations [3354 people or aliases]
  2. Afghanistan [1299]
  3. Syria [1017]
  4. Iraq [744]
  5. Central African Republic [404]
  6. Iran (nuclear proliferation) [391]
  7. North Korea (Democratic People’s Republic of Korea) [308]
  8. Ukraine (Sovereignty) [268]
  9. Somalia [200]
  10. Democratic Republic of the Congo [153]

The blanket term of “Terrorism and Terrorist Financing” sits in 11th place, with 147 names.

Observations

Any interest in easing the customer journey with an online identity is countered by the knowledge that if you get it wrong, you are helping people who have done some ‘seriously bad’ things.

The sanctions list, while open data, is not in a nice format. It can’t be, given the international and vague nature of some of the entries. Given how common some of the names (or name components) are, there is definitely a risk of false matches.

And finally, sanctions can exist against you even after you are assassinated.

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