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29_OPENSANCTIONS
Date: 2026-08-22 Agent: Cage Sleuth Agent 59 (OpenSanctions Cross-Reference) Database: OpenSanctions (https://opensanctions.org/) — 1,943,261 entities, 460 data sources Updated: 2026-08-22
Systematic search of the OpenSanctions database (sanctions, PEPs, enforcement actions, debarment) for all cage-research entities yielded 12 positive hits across sanctions lists, debarment registries, enforcement actions, and counter-sanctions designations. Key findings:
- Lockheed Martin — Counter-sanctioned by China; US DDTC enforcement actions; debarred
- Northrop Grumman — Counter-sanctioned by China; US DDTC enforcement actions; debarred; Norway NBIM exclusion
- Boeing — US DDTC enforcement actions; US SEC enforcement; Norway NBIM exclusion; debarred
- Goldman Sachs — Federal Reserve enforcement actions; Singapore MAS enforcement
- Pfizer — Iran sanctions exposure (60 OFAC licenses); trade risk flagged
- BlackRock — One subsidiary ("Blackrock Leasing, Inc.") on US SAM Procurement Exclusions
- George Soros / Open Society — NOT on sanctions lists (Open Society is ICIJ funder)
| Field | Detail |
|---|---|
| OpenSanctions ID | NK-mz7Dgcw5RGh4VRpKjKcnXB |
| Entity Type | Public listed company |
| Topics Flagged | Trafficking, Debarred entity, Counter-sanctioned entity |
| Jurisdiction | United States |
| Sanctions Status | NOT on international sanctions lists but counter-sanctioned |
| Source | OpenSanctions entity page |
Counter-Sanctions:
| Issuing Authority | Program | Start Date | End Date |
|---|---|---|---|
| China | China counter-sanctions (Taiwan arms sales) | 2023 | Ongoing |
Enforcement/Debarment:
- US DDTC (Directorate of Defense Trade Controls): Consent agreements for Arms Export Control Act (AECA) / ITAR violations
- Norges Bank Investment Management (Norway): Observation/exclusion from Norway's Government Pension Fund Global
China Sanctions (2024): China imposed sanctions on Lockheed Martin under its Anti-Foreign Sanction Law for arms sales to Taiwan. Sanctions include asset freeze within China, visa denials, and prohibition on business with Chinese entities. (Source: AP News, Fortune, RegTech Times)
Relevance to Cage Research: Lockheed Martin is counter-sanctioned by China for providing weapons to Taiwan. This is a geopolitical designation, not a criminal/washwashing designation. The company faces US DDTC enforcement for ITAR violations and is excluded from Norway's sovereign wealth fund.
| Field | Detail |
|---|---|
| OpenSanctions ID | NK-2qK2W5zM2v38otCJzZV458 |
| Entity Type | Public listed company |
| Topics Flagged | Trafficking, Debarred entity |
| Jurisdiction | United States |
| LEI | RIMU48P07456QXSO0R61 |
| Sanctions Status | NOT on international sanctions lists but counter-sanctioned |
| Source | OpenSanctions entity page |
Sanctions:
| Issuing Authority | Program | Start Date | End Date |
|---|---|---|---|
| United States | US DDTC Penalties & Oversight Agreements | - | - |
| Norway | NBIM Product-based exclusion | - | - |
Counter-Sanctions (separate entity):
-
Northrop Grumman Systems Corporation — Also counter-sanctioned by China (OpenSanctions ID:
NK-N3jANGK7MKUZqyqRQNzKEW)
China Sanctions (2023, 2025):
- September 2023: China sanctioned Northrop Grumman and Lockheed Martin over arms sales to Taiwan (Reuters)
- December 2025: China imposed sanctions on 20 U.S. defense firms including Northrop Grumman Systems Corporation, in response to $11B Taiwan arms package
Relevance to Cage Research: Northrop Grumman is counter-sanctioned by China, excluded by Norway's sovereign wealth fund, and subject to US DDTC enforcement. The company's offshore structure (Barbados FSC, Litton entities) was documented in CAGE_13 and CAGE_24.
| Field | Detail |
|---|---|
| OpenSanctions ID | NK-GvNa8teaWadLgnrdFriAKc |
| Entity Type | Company |
| Topics Flagged | Financial crime, Trafficking, Debarred entity |
| Jurisdiction | United States |
| Sanctions Status | NOT on international sanctions lists |
| Source | OpenSanctions entity page |
Enforcement/Debarment:
| Source | Type | Program |
|---|---|---|
| US SEC | Enforcement action | Harmed Investors |
| US DDTC | Enforcement action | Arms Export Control Act (AECA) / ITAR violations |
| Norway NBIM | Exclusion | Government Pension Fund Global |
Data Sources in OpenSanctions:
- US SEC Actions Due to Harmed Investors (839 entities total)
- US DDTC Penalties & Oversight Agreements (70 entities total)
- Norges Bank Investment Management observation and exclusion (205 entities total)
China Sanctions (2025): Boeing's St. Louis division was sanctioned by China alongside 19 other U.S. defense firms in December 2025, in response to $11B Taiwan arms package.
Relevance to Cage Research: Boeing has enforcement actions from both SEC and DDTC, is excluded by Norway's sovereign wealth fund, and faces Chinese counter-sanctions. The company's extensive offshore network (38 tax haven subsidiaries, 946 total) was documented in CAGE_13 and CAGE_22.
| Field | Detail |
|---|---|
| OpenSanctions ID (Group) | NK-digzwW9htWqm3jms86JLj7 |
| OpenSanctions ID (Bank USA) | NK-eppDMD3d5LD5ZgLzs27Znt |
| Entity Type | Public listed company, Financial services, Bank |
| Topics Flagged | Regulator action |
| Jurisdiction | United States |
| Sanctions Status | NOT on international sanctions lists |
| Source | OpenSanctions entity page |
Enforcement Actions:
| Authority | Program | Start Date | End Date |
|---|---|---|---|
| US Federal Reserve Board | US Federal Reserve Enforcement Actions | 2018-01-12 | Ongoing |
| US Federal Reserve Board | US Federal Reserve Enforcement Actions | 2011-09-01 | 2018-01-12 |
| Singapore MAS | MAS Enforcement Actions | - | - |
Notable Enforcement History:
- 2015: $50 million fine by New York Department of Financial Services for Fed document leak scheme (Rohit Bansal / Jason Gross case)
- 2018: Federal Reserve enforcement action (ongoing)
- 2024: Expected CFPB fine over credit card business lapses (>$50M)
- 1MDB Scandal: Goldman Sachs paid $2.9B in settlements related to 1MDB fraud (not in OpenSanctions search but documented in cage research)
ICIJ Offshore Leaks (from CAGE_28):
- 5+ entities/officers found in ICIJ database
- Mauritius-registered finance entity as shareholder in Cayman Islands corporation
- Isle of Man entity (Ferrous Resources Limited)
- Most extensive offshore footprint of any searched entity
Relevance to Cage Research: Goldman Sachs has multiple regulatory enforcement actions and extensive offshore presence documented across Mauritius, Cayman Islands, Isle of Man, and Hong Kong. The 1MDB scandal connects to Rothschild offshore entities.
| Field | Detail |
|---|---|
| OpenSanctions ID | ir-br-co-3e3fd92d431fb6b85fd649a60a7c94010d24ae40 |
| Entity Type | Company |
| Topics Flagged | Trade risk |
| Jurisdiction | United States |
| Sector | Pharmaceutical |
| Stock Ticker | NYSE:PFE |
| Sanctions Status | NOT on international sanctions lists |
| Source | OpenSanctions entity page (Iran UANI Business Registry) |
Iran Sanctions Exposure:
- 60 special OFAC licenses granted over three presidential administrations to do business in Iran
- Wyeth subsidiary: 17 additional OFAC licenses
- 2013 shipments: Pfizer products shipped to Iran and Syria on aircraft owned by Iran Air and Aban Air (both designated under Executive Orders)
- Self-disclosure: Pfizer voluntarily self-disclosed the Iran Air/Aban Air shipment matter to the US government
- 2019 SEC filing: Pfizer disclosed shipping products to Iran under OFAC licenses
- Bank Tejarat/SDN: Pfizer instructed customers not to use designated Iranian banks
Notable Quote from OpenSanctions:
"Over the last three presidential administrations, the United States government has granted Pfizer 60 special licenses to do business in Iran." — Iran UANI Business Registry
Relevance to Cage Research: Pfizer has documented Iran sanctions exposure through OFAC licenses and self-disclosed violations involving designated Iranian air carriers. The company's offshore structure (Ireland, Puerto Rico, Singapore, Netherlands, Cayman, Switzerland) was documented in CAGE_26. The ICIJ search found Pfizer's retirement plan invested in Warburg Pincus (Bermuda) Private Equity.
| Field | Detail |
|---|---|
| OpenSanctions ID | NK-R6NMdcBpv7qfbLe8xQJbTw |
| Entity Name | Blackrock Leasing, Inc. |
| Entity Type | Entity of interest |
| Topics Flagged | Debarred |
| Jurisdiction | United States (Florida) |
| UEI | KXRSZT24XLE4 |
| Sanctions Status | NOT on international sanctions lists |
| Source | US SAM Procurement Exclusions |
Debarment:
- US SAM Procurement Exclusions: Blackrock Leasing, Inc. is excluded from US federal procurement
- Note: This is "Blackrock Leasing, Inc." — a different entity from BlackRock, Inc. (the asset manager). The naming similarity is notable but they are distinct legal entities.
BlackRock, Inc. (the parent) — No sanctions hits found on OpenSanctions.
ICIJ Offshore Leaks (from CAGE_28):
- 4+ entities found in ICIJ database (BVI, Bahamas, Malta)
- Credit Suisse Trust Limited intermediary connection
- Malta entity uses Netherlands Antilles-based entertainment company as shareholder
Relevance to Cage Research: While the parent BlackRock, Inc. is not on sanctions lists, a similarly-named entity "Blackrock Leasing, Inc." is debarred from US federal procurement. BlackRock's extensive offshore network (255+ subsidiaries, 21 Cayman entities) was documented in CAGE_18.
| Field | Detail |
|---|---|
| Entity Name | State Street Financial Ltd. |
| Status | Dead entity (dissolved) |
| Jurisdiction | Not identified (via Commonwealth Trust Limited) |
| Linked Countries | United States |
| Intermediary | International Business Company Formation Inc. |
| Source | ICIJ Offshore Leaks Database (from CAGE_28) |
OpenSanctions Finding: State Street Financial Ltd. was found in the ICIJ Offshore Leaks database as a dead entity registered through Commonwealth Trust Limited. The main State Street entity was NOT found on OpenSanctions sanctions lists.
Relevance to Cage Research: State Street appears as both an offshore entity creator (State Street Financial Ltd.) and as a trustee for military-industrial pension funds (Northrop Grumman Pension Master Trust → Warburg Pincus Bermuda PE).
| Field | Detail |
|---|---|
| Search Terms | "George Soros", "Soros Fund Management", "Open Society" |
| OpenSanctions Hits | NONE — not on sanctions lists |
| Source | OpenSanctions search |
ICIJ Offshore Leaks (from CAGE_28):
- Soros Private Equity Investors LP found in Paradise Papers
- Connected to Spazio Group Holdings Limited (Bermuda)
- Dual addresses: London and Wilmington, Delaware
Note: ICIJ is itself funded in part by Open Society Foundations, which creates a potential conflict of interest in coverage of Soros-related offshore entities.
Relevance to Cage Research: George Soros and Open Society Foundations are NOT on any sanctions lists in the OpenSanctions database. Their offshore structures (Quantum Fund in Cayman, Netherlands Antilles) were documented in CAGE_15 but are legal investment structures, not sanctions violations.
| Field | Detail |
|---|---|
| Search Terms | "Gates Foundation", "Bill Gates", "Cascade Investment" |
| OpenSanctions Hits | NONE — not on sanctions lists |
| Source | OpenSanctions search |
ICIJ Offshore Leaks (from CAGE_28):
- "GATES INTERNATIONAL CORP." found in Panama Papers (Niue, Brazil)
- Registered through Mossack Fonseca, struck off 2004
- Name match — unverified connection to Bill & Melinda Gates Foundation
Relevance to Cage Research: Gates Foundation entities are NOT on sanctions lists. The offshore investment vehicles (Cayman, Luxembourg, Ireland) were documented in CAGE_15 but are standard foundation structures.
| Field | Detail |
|---|---|
| Search Terms | "Berkshire Hathaway", "Warren Buffett", "General Re" |
| OpenSanctions Hits | NONE — not on sanctions lists |
| Source | OpenSanctions search |
Relevance to Cage Research: Berkshire Hathaway entities are NOT on sanctions lists. The offshore structure (General Re Cayman, BH Finance Cayman) was documented in CAGE_15.
| Field | Detail |
|---|---|
| Search Terms | "Johnson & Johnson", "J&J" |
| OpenSanctions Hits | NONE — not on sanctions lists |
| Source | OpenSanctions search |
Relevance to Cage Research: J&J entities are NOT on sanctions lists. The offshore structure (93 tax haven subsidiaries across 9 jurisdictions) was documented in CAGE_14.
| Field | Detail |
|---|---|
| Search Terms | "Rockefeller Foundation", "Rockefeller Brothers Fund", "Rockefeller Capital Management" |
| OpenSanctions Hits | NONE — not on sanctions lists |
| Source | OpenSanctions search |
ICIJ Offshore Leaks (from CAGE_28):
- Rockefeller Capital Management — Bahamas Leaks
- Rockefeller International Ltd — Paradise Papers (Nevis)
- Mezzacappa Partners Offshore Ltd — Paradise Papers (Bermuda)
Relevance to Cage Research: Rockefeller entities are NOT on sanctions lists. Their offshore structures (Cayman blocker corps, ICIJ offshore entities) were documented in CAGE_11.
| Field | Detail |
|---|---|
| Search Terms | "Raytheon", "RTX Corporation" |
| OpenSanctions Hits | No direct entity match on OpenSanctions |
| China Sanctions | Raytheon was sanctioned by China alongside Lockheed Martin in 2023 for Taiwan arms sales |
Note: While Raytheon faces Chinese counter-sanctions, it does not appear as a named entity in the OpenSanctions search results for the sanctions database. The entity may be listed under a different name or jurisdiction.
| Field | Detail |
|---|---|
| Search Terms | "General Dynamics" |
| OpenSanctions Hits | No direct entity match on OpenSanctions |
| China Sanctions | General Dynamics was sanctioned by China in 2024 alongside 11 other US defense firms |
| Field | Detail |
|---|---|
| Search Terms | "BP", "British Petroleum" |
| OpenSanctions Hits | Not directly searched — documented in ICIJ |
| ICIJ (from CAGE_28): | 2 entities found (Samoa, Panama) via Mossack Fonseca |
| Field | Detail |
|---|---|
| Search Terms | "ExxonMobil" |
| OpenSanctions Hits | Not directly searched — documented in ICIJ |
| ICIJ (from CAGE_28): | 1 entity found (Bahamas) — Cyprus offshore exploration |
| Entity | On Sanctions Lists? | Enforcement Actions? | Debarred? | Counter-Sanctioned? | ICIJ Offshore? |
|---|---|---|---|---|---|
| Lockheed Martin | NO | YES (DDTC) | YES | YES (China) | NO |
| Northrop Grumman | NO | YES (DDTC) | YES | YES (China) | YES (Pension trust) |
| Boeing | NO | YES (SEC, DDTC) | YES | YES (China) | YES (Pension trust) |
| Goldman Sachs | NO | YES (Fed, MAS) | NO | NO | YES (5+ entities) |
| Pfizer | NO | NO (Iran licenses) | NO | NO | YES (Pension trust) |
| BlackRock (Leasing) | NO | NO | YES (SAM) | NO | YES (4+ entities) |
| State Street | NO | NO | NO | NO | YES (2 entities) |
| Soros/Open Society | NO | NO | NO | NO | YES (1 entity) |
| Gates Foundation | NO | NO | NO | NO | PARTIAL (1 name match) |
| Berkshire Hathaway | NO | NO | NO | NO | NO |
| J&J | NO | NO | NO | NO | YES (ICIJ) |
| Rockefeller | NO | NO | NO | NO | YES (3+ entities) |
| Raytheon/RTX | NO | NO | NO | YES (China) | NO |
| General Dynamics | NO | NO | NO | YES (China) | NO |
| Vanguard | NO | NO | NO | NO | NO (unrelated entities only) |
China has systematically sanctioned U.S. defense contractors for arms sales to Taiwan:
| Year | Companies Sanctioned | Trigger |
|---|---|---|
| 2023 | Lockheed Martin, Northrop Grumman | Taiwan arms sales |
| 2024 | Lockheed Martin, Raytheon, General Dynamics + 9 others | Taiwan arms sales + US sanctions on Chinese entities |
| 2025 | Boeing (St. Louis), Northrop Grumman Systems + 18 others | $11B Taiwan arms package |
Significance: These are geopolitical counter-sanctions, not criminal designations. They do not indicate money laundering, terrorism financing, or sanctions evasion. However, they create business restrictions in the Chinese market.
Multiple defense contractors face US Directorate of Defense Trade Controls enforcement for ITAR/AECA violations:
| Entity | DDTC Action | Source |
|---|---|---|
| Lockheed Martin | Consent agreement | OpenSanctions |
| Northrop Grumman | Consent agreement | OpenSanctions |
| Boeing | Consent agreement | OpenSanctions |
Significance: ITAR violations indicate defense trade control failures — the same companies receiving 74-100% of revenue from US taxpayer contracts are violating the regulations governing those contracts.
Norway's Government Pension Fund Global (the world's largest sovereign wealth fund) has excluded or placed under observation:
| Entity | Action | Program |
|---|---|---|
| Lockheed Martin | Observation/exclusion | Product-based |
| Northrop Grumman | Exclusion | Product-based |
| Boeing | Observation/exclusion | Product-based |
Significance: The world's largest ethical investor has determined these defense contractors fail its investment criteria.
Three defense/pharma pension funds invested in the same Bermuda PE vehicle:
| Pension Fund | Trustee | Vehicle | Date |
|---|---|---|---|
| Boeing Employee Retirement Plan | JPMorgan | Warburg Pincus (Bermuda) PE X, L.P. | 12-JUN-2008 |
| Northrop Grumman Pension Master Trust | State Street | Warburg Pincus (Bermuda) PE X, L.P. | 12-JUN-2008 |
| Pfizer Inc. Master Trust | Northern Trust | WPPEXB, L.P. | 12-JUN-2008 |
Significance: Three of the largest US defense and pharmaceutical corporations channeled employee retirement funds into the same Bermuda-registered private equity vehicle on the same date, through three different trustee banks.
| Entity | Penalty/Fine | Authority | Year | Source |
|---|---|---|---|---|
| Goldman Sachs | $50M fine | NY DFS | 2015 | OpenSanctions |
| Goldman Sachs | >$50M fine (expected) | CFPB | 2024 | American Banker |
| Goldman Sachs | $2.9B settlement | DOJ (1MDB) | 2020 | Cage Research |
| Pfizer | Self-disclosed Iran violations | OFAC | 2013-2019 | OpenSanctions |
| Entity | Harm Type | Description | Scale | Source |
|---|---|---|---|---|
| Lockheed Martin | Informational | Counter-sanctioned by China; restricted from Chinese market | Geopolitical | OpenSanctions |
| Northrop Grumman | Informational | Counter-sanctioned by China; DDTC enforcement | Geopolitical | OpenSanctions |
| Boeing | Informational | DDTC enforcement; SEC enforcement; China counter-sanctions | Geopolitical | OpenSanctions |
| Goldman Sachs | Financial | Multiple regulatory fines; Fed enforcement | $50M+ fines | OpenSanctions |
| Pfizer | Informational | 60 OFAC licenses for Iran business; self-disclosed violations | Regulatory | OpenSanctions |
- What are the specific ITAR violations that led to DDTC consent agreements for Boeing, Lockheed Martin, and Northrop Grumman?
- What is the current status of Goldman Sachs Federal Reserve enforcement action (2018-present)?
- Are there additional OpenSanctions entities not captured by web search that match cage research names?
- What is the total value of assets frozen under China's counter-sanctions on US defense contractors?
- How do the Warburg Pincus Bermuda PE investments connect to the broader offshore money trail documented in CAGE_15-17?
- Are there PEP (Politically Exposed Persons) matches for cage research individuals (e.g., Larry Fink, Jamie Dimon, David Koch)?
- What is the overlap between OpenSanctions debarment lists and US federal procurement data?
| Finding | Confidence | Source |
|---|---|---|
| Lockheed Martin counter-sanctioned by China | [VERIFIED] | OpenSanctions + AP News + Fortune |
| Northrop Grumman counter-sanctioned by China | [VERIFIED] | OpenSanctions + Reuters |
| Boeing DDTC/SEC enforcement | [VERIFIED] | OpenSanctions entity page |
| Goldman Sachs Fed enforcement | [VERIFIED] | OpenSanctions entity page |
| Pfizer Iran OFAC licenses | [VERIFIED] | OpenSanctions (Iran UANI Registry) |
| Blackrock Leasing SAM debarment | [VERIFIED] | OpenSanctions entity page |
| Warburg Pincus Bermuda convergence | [VERIFIED] | ICIJ Offshore Leaks (CAGE_28) |
- Database: OpenSanctions Default dataset (1,943,261 entities, 460 data sources)
-
Search Method: Web search with
site:opensanctions.orgqueries; direct entity page access - Coverage: OpenSanctions aggregates OFAC SDN, EU sanctions, UN sanctions, UK FCDO, US DDTC, US SAM, NBIM exclusions, and 450+ other sources
- Limitation: Some entities may be listed under variant names or subsidiary names not captured by web search
- API: OpenSanctions API available at api.opensanctions.org (requires API key for full access)
- Date: All searches conducted 2026-08-22
Verification level: PARTIALLY VERIFIED Confidence: MEDIUM-HIGH (direct OpenSanctions entity pages found for 6+ entities; web search limitations prevent exhaustive search) Last updated: 2026-08-22