SpyLedger
Methodology
SpyLedger is built to be cited, so the rules behind it are public. It records only facts of public government record, each rebuilt from a primary source and linked. This page documents the authority taxonomy, the scope and fairness rules, the ethical guardrail, and how to dispute an entry.
The authority taxonomy
A company can appear on several different government lists, and they do not mean the same thing. SpyLedger labels every designation with its authority and its legal type, because collapsing them — calling an export-control listing or an equipment rule a “sanction” — is both wrong and unfair. The four types in the record:
- Sanction (asset-blocking)
- Property within US jurisdiction is blocked and US persons are generally prohibited from dealings (e.g. OFAC SDN List).
- Export control
- A license is required to export US-origin items/technology to the entity, typically reviewed under a presumption of denial (e.g. BIS Entity List). It is not an asset freeze.
- Equipment-authorization restriction
- Covered equipment cannot receive new FCC authorization for certain purposes. It is not a sanction or asset freeze and does not ban all of the company’s products (e.g. FCC Covered List).
- Investment restriction
- US persons are barred from buying or selling the company’s publicly traded securities. It is not an asset freeze or a ban on ordinary commercial trade (e.g. Treasury NS-CMIC List).
Each program code on a designation (RUSSIA-EO14024, CMIC-EO13959, SDGT and the like) corresponds to a specific OFAC authority; the sanctions-programs reference explains what each one means. The clearest example is the FCC Covered List: it restricts new equipment authorizations for certain national-security-sensitive purposes. It is not an asset freeze and does not ban all of a company's products in the United States, so SpyLedger renders it as an equipment-authorization restriction with its verbatim scope, never as a flat sanction.
Scope — and fairness
- Designations are rebuilt from primary public-domain feeds — US BIS Entity List, US OFAC SDN, US Treasury NS-CMIC, the US FCC Covered List, and the EU consolidated list — each with a source link. Designation status is a statement of public government record.
- No designation is stated plainly. Where a vendor carries no designation, the record says so explicitly. Inclusion in SpyLedger is not itself an accusation — several tracked vendors have no designation at all.
- Removed listings are marked historical. A delisted or rescinded action (for example, a listing later removed after corporate reforms) is shown as historical, not active.
- Look-alike entities are not conflated. A designation against one legal entity is not attributed to a similarly named affiliate unless the primary record names that entity.
- No customer-deployment claims in v0. Which government uses which product is the highest-evidence, highest-risk claim in this field; it is curated separately and not published here.
Ethical guardrail — track the watchers, not the watched
SpyLedger documents the surveillance industry and the governments that regulate it — the powerful side of the ledger. It is the deliberate inverse of surveillance. It carries no victim or target identities, ever; no individual personal data below the corporate-officer line; and no raw leaked material — where reporting derives from a leak, SpyLedger would cite the published analysis, never republish a dump.
Corrections & disputes
Any named entity can dispute an entry. Because every designation is sourced to a primary government record, most disputes resolve by checking the linked source. Where a status has changed — a delisting, a corrected scope, a misattributed entity — the correction is applied and the entry updated. Reach us via the contact page; substantiated corrections are reflected in the next build. SpyLedger is released under CC BY 4.0, so downstream copies should re-pull to pick up corrections.
Record current as of the 2026-06-22 build. Back to SpyLedger · see also Verboten and the site methodology.