I’ve been working on this for a while – as a learning tool, correcting and refining is more instructive to me than getting a good result and asking for the master prompt.

A few things to point out:

• I haven’t run this against aircraft designations “live” yet, so this part might not be precise
• OFAC doesn’t use any delimiters except for things that can have multiple values, so you don’t know, at a glance, when a field’s label ends and its value begins. I’ve generally steered Gemini by listing all the labels I’ve seen
• Sometimes OFAC doesn’t break down the data at all – cargo vessel types are immediately followed by the flag state with delimiter (although I guess you could treat the whole thing as a compound data element)
• OFAC clearly has a bias towards sanctioning entities – why else would there be party types of “aircraft”, “vessel” and “individual”, but nothing for entities?

Anyhow, here’s the prompt – if you see some logic that will break, let me know:

OFAC addition or deletion listings are in the following format:

All OFAC listings finish with the following:

1. The type of party (Individual, Vessel, Aircraft) in parentheses may be present- if not present, the listing refers to an entity. Entities can also be identified more easily if the section of the OFAC identifies the listings which follow as entities.
2. After that. a series of OFAC program tags (defined at Information on OFAC sanctions lists program tags and their definitions.),appears, in square brackets – there will always be at least one.
3. Next, optionally, in parentheses, the text “Linked To:” and other parties with which the listed party is associated, with multiple instances separated by semi-colons
4. And the listing terminates with a period.

And the first element in all listings is the primary name.

The information between the primary name and the party type depends on the party type:

For entities:

1. After the primary name, in parentheses, is  an optional series of aliases, prefixed by “a.k.a.” and separated by semicolons
2. Next, after a comma, are associated addresses, each followed by a semicolon
3. Next are a series of fields consisting of labels (e.g. Identification Number, Registration number), possibly terminated with a colon (e.g. “Secondary sanctions risk:”), a value, and terminated by a semicolon, except for the last field
4. The Registration Number field may have subfields such as issuing country (in parentheses) and issue date.
5. As a reminder, the final field is not terminated by a semi-colon but is followed by the list of program tags, the optional Linked To information and the final period.

Here is an example: 

ARIES GLOBAL INVESTMENT LTD (a.k.a. ARIES GLOBAL INVESTMENT LIMITED), Room 2611, 26th Floor, Southeast Technology R&D Center, 438, Jincheng Lu, Xiaoshan Qu, Hangzhou, Zhejiang, China; Rm A 20/F ZJ 300, 300 LOCKHART RD, Wan Chai, Hong Kong, China; Identification Number IMO 0052971; Registration Number 76957722 (Hong Kong) issued 19 Aug 2024 [VENEZUELA-EO13850]. 

For individuals:

1. After the primary name, in parentheses, is either a series of aliases, prefixed by “a.k.a.” and separated by semicolons, or a vessel call sign
2. After a comma, are associated addresses (full address, city and country or country), each followed by a semicolon
3. Next are a series of fields consisting of labels (e.g. DOB, nationality, Gender, Secondary Sanctions Risk, Cedula, possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
4. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

Here is an example: 

ARAYA NAVARRO, Jimena Romina (a.k.a. “ARAYA, Jimena”; a.k.a. “Rosita”), Venezuela; Colombia; DOB 05 Sep 1983; nationality Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Cedula No. 16011070 (Venezuela) (individual) [SDGT] [TCO] (Linked To: TREN DE ARAGUA). 

For cargo vessels:

1. After the primary name, optionally, in parentheses, a vessel call sign appears
2. Next appears a description of the vessel, and the flagging country, with multiple instances separated by semi-colons (and subsequent ones may be preceded by “Other Vessel Flag”
3. Next are a series of fields consisting of labels (e.g. Year of Build, Identification Number, Registration number, MMSI), possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
4. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

Here is an example: 

VALIANT (VRXH3) Crude Oil Tanker Hong Kong flag; Other Vessel Flag China; Vessel Year of Build 2009; Vessel Registration Identification IMO 9409247; MMSI 477206500 (vessel) [VENEZUELA-EO13850] (Linked To: ARIES GLOBAL INVESTMENT LTD).

For aircraft:

1. After the primary name, there is a semi-colon
2. Next are a series of fields consisting of labels (e.g. Manufacture Date, Model, Operator, Manufacturer’s Serial Number (MSN), Tail Number), possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
3. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

Here is an example: 

EP-MJG; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 474; Aircraft Tail Number EP-MJG; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). 

OFAC change listings consist of the old listing, followed by “-to-“, followed by the new listing.

Take no action on this information until prompted further.