The Gap

Designation Events by Jurisdiction and Window

The first three windows (722 events) are the record through August 10, 2026. The refresh window adds 183 events: US 168, Canada 15; the EU, the UK and Australia made none. They are listed on the Sanctions Monitor. Open gaps stand at 259 across 58 profiles after every gap cell was rechecked against the official lists.

The last column is not a count of events but of absences: documented parties that jurisdiction screened and has not designated. Read across, it is the case for mirror-listing; read down, it is the order of work.

The Widest Gaps

The 58 profiles carrying at least one open gap, worst first. Every row here is a party this project documents and at least one screened government has not designated. 42 of them are open in all five jurisdictions at once; these are the Do Not Touch names, which by construction have been re-screened against all five sanctions lists and matched on none of them. A row of five hollow marks is not missing data. It is the finding.

Eight Asks

Ordered by strength of evidence and size of the gap. Each ask copies as a formatted, sourced paragraph, with the address of this page appended, ready to paste into a letter.

1. 01
   Mirror-List the Post-MOU 170

   The EU, UK, Canada and Australia should designate the window’s US targets by network. Canada and Australia start from zero; neither made a single Iran-related designation in the ten weeks after June 1.

   In this record: Sanctions Monitor · Gap map totals

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2. 02
   Send OFAC the 25-Party BIS List

   Every BIS-OFAC gap party on the Do Not Touch screen already carries a Federal Register citation. Ten months between an Entity List action and an SDN review is too long.

   In this record: Do Not Touch, Register A

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3. 03
   Apply Magnitsky-Style Measures to the EU-Only Judges

   Four of the five judges the EU sanctioned on July 24, 2026 have no US, UK, Canadian or Australian counterpart. Priority goes to Abolfazl Ameri Shahrabi, the only judge anywhere tied by name to sentencing Nobel laureate Narges Mohammadi.

   In this record: Designation events · Network exhibits

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4. 04
   Designate IMCR by Name at Treasury

   A Justice Department complaint already ties the Islamic Movement of Companions of the Right’s alleged commander to eighteen attacks in Europe and two in Canada. The UK acted in July 2026; the US, EU, Canada and Australia have not.

   In this record: Designation events

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5. 05
   Designate MAPNA’s Parent, and Examine MAPNA Europe GmbH

   The EU designated MAPNA Group on July 30, 2026 as energy-ministry-controlled with nuclear-proliferation risk. The US has designated only one subsidiary, and a MAPNA subsidiary continues operating openly out of Düsseldorf.

   In this record: Designation events

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6. 06
   Issue a Hormuz Insurance Advisory

   The Persian Gulf Marine Insurance Company and HormuzSafe sell shipowners protection against a risk Iran itself creates. Regulators should warn shipowners off the scheme before more of them fund it unknowingly.

   In this record: Network exhibits · Entity register

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7. 07
   Build FinCEN’s Typologies into Bank Compliance Programmes

   FinCEN Alert FIN-2026-Alert002’s red flags for Iran-linked crypto and shadow-banking rails already worked once, in the August 7 action against Shelbit and Aban Tether. Banks should not need a second alert to act on them.

   In this record: Network exhibits

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8. 08
   Encourage Do Not Touch Adoption

   The scrutinized-companies divestment mechanism already on the books in dozens of US states can be pointed at the 68 names on this project’s Do Not Touch screen today, without waiting on any government designation.

   In this record: Do Not Touch

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The same asks, grouped by who can act on them, are on Take Action.