Hallo, I helped suggest improvements to the spreadsheet years ago, and I’m interested in improving the China sanction list again. I noticed some duplicated sanction records, incorrect dates, and duplication of sanction programs (AFSL and the Countermeasure List refer to the same list). How can I help?
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Hi, thank you for reaching out! I assume that you are referring to the cn_sanctions dataset. As you mentioned, this dataset is unfortunately not maintained in an automated fashion like most of our other datasets because China does not publish structured data on individuals and entities targeted by the country’s sanctions legislation.
I’m not too deep on the whole topic, could you elaborate on the mistakes you discovered? In particular, do you have more context on the issue you discovered in the sanctions program taxonomy (ASFL vs Countermeasure List)? Thanks a lot in advance!
Cc @eric and @nvmbrasserie
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The Chinese sanction framework has the follow programs:
| Program | OpenSanctions ID | Legislation that created list | Sanctioning authority |
|---|---|---|---|
| Countermeasures List | CN-CML, CN-AFSL | Anti-Foreign Sanctions Law (AFSL) | Any government ministry, but so far only the Ministry of Foreign Affairs and the Ministry of Commerce |
| Export Control List | CN-ECL | Regulations on the Export Control of Dual-use Items | Ministry of Commerce |
| Export Control Watchlist | CN-ECWL | Regulations on the Export Control of Dual-use Items | Ministry of Commerce |
| Unreliable Entity List | CN-UEL | Ministry of Commerce | |
| None specified. Some entities in Taiwan are sanctioned under an unspecified program related to supposed pro-independence | None | Unknown | Taiwan Affairs Office of the State Council / Taiwan Work Office of the CCP (same agency with two names) |
| Diehard “Taiwan Independence” Separatists List | None | Unknown | Taiwan Affairs Office of the State Council / Taiwan Work Office of the CCP (same agency with two names) |
| Accomplice of “Taiwan Independence” Separatists List | None | Unknown | Taiwan Affairs Office of the State Council / Taiwan Work Office of the CCP (same agency with two names) |
AFSL, “List of Targets of Countermeasures”, and the Countermeasures List refer to the same program, because ASFL specifies only one mechanism for sanctioning, which is to list entities in the Countermeasures List and punish those entities on the list (and their associates). Therefore, all entities sanctioned that are attributed to the AFSL or the “List of Targets of Countermeasures” should be unified under the Countermeasures List program (CN-CML) instead.
Likewise, “List of Export Controls” in the spreadsheet should be attributed to the Export Control List program (CN-ECL).
I believe sanctions by the Taiwan Affairs Office should not be classified as counter-sanction because they are not issued to retaliate against a sanction from Taiwan. They are simply sanctions.
I went through the spreadsheet and annoucements from sanctioning authorities and found specific inaccuracies / improvements to the spreadsheet:
- Rows 1-6: Dates should be December 2, not February 12
- Row 46 duplicates with Row 129
- Row 68: Change name of entity to “Hong Kong Democracy Council”. Move “Hong Kong Democratic Council” to alias, as it was a spelling mistake made by the Chinese Foreign Ministry.
- Rows 72-74: These entities should be listed under the Diehard “Taiwan Independence” Separatists List
- Rows 79-80: They are categorized as “organizations associated with Diehard ‘Taiwan Independence’ Separatists,” which is not itself a list. I am unsure whether to include these in the diehard separatists sanction program.
- Rows 81-84: They are categorized as “enterprises that donated to organizations with Diehard ‘Taiwan Independence’ Separatists,” which is not itself a list. I am unsure whether to include these in the diehard separatists sanction program.
- Rows 87-93: These entities should be listed under the Diehard “Taiwan Independence” Separatists List.
- Row 117: Missing Ministry of Foreign Affairs as the sanction authority.
- Rows 169-181 duplicate with Rows 263-275.
- Rows 169-181: the program should be Countermeasures List (CN-CML).
- Rows 182-190 duplicate with Rows 277-284.
- Rows 182-190: the program should be Countermeasures List (CN-CML).
- Row 191: the program should be Countermeasures List (CN-CML), and missing Ministry of Foreign Affairs as the sanction authority.
- Rows 194-212 duplicate with Rows 237-255.
- Row 220: Add Wikidata ID Q29886495
- Row 228: Spelling mistake. It should be Skydio not Skedio in the summary
- Row 245: Charles Woodburn is British not American.
- Rows 292-331: Sanction actions are misdated. They should be February 24, not February 26.
Other comments
- I have found 209 sanctioned entities missing from the spreadsheet. It is too long to include it here.
- I suggest all source URLs to be archived on Wayback Machine as Chinese government websites are very prone to link rot. Some of the links in the spreadsheet are already gone.
- Some sanctions are temporarily suspended in enforcement or are withdrawn through bilateral discussions between the Chinese government and a foreign government. The dates of withdrawal for them are not always known. Thus it can be difficult to fill the “end date” column.
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This is really great research! I really would like us to develop a more automated approach to retrieving this data in the future, so before I beg you for the actual entity list - want to share some about how you got this insight? I assume an LLM was involved, but the results point to a really precise and well-targeted prompt. Curious 
In the end, we’d really like to get to a place where we have a set of press release index pages that we can auto-crawl regularly and then feed into a custom prompt to generate candidate designations for review.
One (much simpler) thing we could do right now to make this process more structured: move the China sanctions to a CSV file in our repo, so that we could discuss, verify and accept changes via a PR? Would that work for you?