Who appears on more than one sanctions or exclusion list at once?

The HHS Office of Inspector General (OIG LEIE), the General Services Administration (SAM.gov), and each state Medicaid program publish exclusions independently. A party can be on several at once, and no one list reveals that. Joining them on the shared National Provider Identifier shows that 43.2% of the 11,093 NPI-identified excluded providers are listed by more than one authority — and 908 by all three. This is the overlap the graph computes; it is exactly what a screen against any single list would miss.

Six published lists, with the active record count and the snapshot date each was read as-of. The three U.S. exclusion registries and the EU/UN pair participate in an exact-identifier overlap join; the OFAC list is profiled for scale but shares no machine key with the others, so it is not cross-joined.

The membership distribution across the three U.S. exclusion registries. Buckets are mutually exclusive, so the first three rows sum to the distinct total; the fourth row is the overlap (two or more) called out on its own.

Distinct providers (by NPI) on each registry along the diagonal, and the pairwise intersections off it. Read a cell as “providers on the row registry that are also on the column registry.” The matrix is symmetric; 908 providers sit in all three at once.

For the overlapping providers recorded on the OIG LEIE, the statutory basis of the federal exclusion (the OIG's own exclusion-type code under 42 U.S.C. § 1320a-7). A provider can carry more than one code, so the shares are of the category total, not of distinct providers. This is the published code, not any conduct attributed to a named person.

The LEIE-recorded state of the overlapping (two-or-more-list) providers — the geography of the overlap. The largest states track population and program-integrity activity; this is a state cut, not a single state's own list.

The international sanctions lists share no contracting key with the U.S. exclusion registries, so they are not cross-joined to them. They do, however, cross-reference each other: the EU Consolidated Financial Sanctions List carries the UN Security Council's own published reference number for each UN-derived designation. Of 5,994 active EU designations, 87 carry such a UN reference and 84 resolve to an active UN listing — parties that appear on both the EU and UN lists at once, on the publisher's own cross-reference rather than our inference. No OFAC-to-EU or OFAC-to-UN match is attempted, because no shared identifier exists and a name-based match is not safe to publish.

• Exact identifiers only. The U.S. overlap is keyed on the National Provider Identifier, the one machine key the three exclusion registries share. The international overlap uses the EU's own published UN reference number. No fuzzy name matching is used anywhere.
• NPI-identified slice. Only records carrying a valid 10-digit NPI can join the U.S. overlap. Most SAM.gov exclusions carry no NPI (they are non-healthcare or name-only), so this counts the NPI-identified provider slice, not the whole registry.
• No cross-system claim. The OFAC, EU, and UN sanctions lists are not joined to the U.S. exclusion registries — different identity spaces, no shared key. No party on a sanctions list is matched to a party on an exclusion list here.
• No party named, no score. Every figure is an aggregate count. This study names no individual or entity, produces no per-person report or dossier, and assigns no risk score. An identifier on more than one list is a count of administrative records, not a judgment.

The study aggregates the current bitemporal slice of the signed source tables in the fonteum-platform warehouse. The U.S. overlap joins three exclusion registries — public.oig_leie_exclusions (OIG LEIE), public.sam_exclusions (SAM.gov), and public.state_exclusions (state Medicaid lists, 13 states) — on the 10-digit National Provider Identifier, normalized to a valid form (leading digit 1-9). Set membership is a three-way GROUP BY over the distinct NPI sets; the pairwise matrix and the all-three figure are intersections of those sets.

The international cross-reference joins public.eu_sanctions_listings to public.un_sanctions_listings on the EU-published UN reference number (un_id → the UN record's un_data_id / reference_number), filtered to valid_to IS NULL. Every published figure is re-derivable from the SQL below, whose expected-result comments match the committed JSON snapshot exactly. Each source feed refreshes on its own cadence and every snapshot is content-hashed and witness co-signed.

Re-derive every figure on this page from the published artifacts:

• Reproducible SQL — the exact set-membership and intersection queries, with expected-result comments.
• Download JSON · Download CSV — the committed overlap snapshot.

Every figure here traces to signed source snapshots, not our word for it. Each daily pull is content-hashed and chained; you can re-hash the published bytes against the attestation yourself.

Re-check a snapshot → — re-hash any Fonteum snapshot and confirm the bytes match the chained attestation.

Fonteum (2026). Sanctioned Across Borders: Cross-List Overlap of U.S. and International Sanctions & Exclusion Lists. Derived from OIG LEIE, SAM.gov Exclusions, state Medicaid exclusion lists, and the EU and UN consolidated sanctions lists (snapshots 2026-06-25). https://fonteum.com/gov/research/sanctioned-across-borders-2026

Canonical URL: https://fonteum.com/gov/research/sanctioned-across-borders-2026 · License: U.S. Government Works (public domain; 17 U.S.C. §105)

• This counts active records on each list's snapshot date, not a historical time series. Reinstated or delisted parties age off and are not counted.
• The U.S. overlap is restricted to records carrying a valid NPI. The true overlap including name-only and UEI-only exclusion records is necessarily larger; this is the exact-identifier floor, not a ceiling.
• The category and state cuts use the OIG LEIE fields for the overlapping providers present on the LEIE; an overlapping provider on SAM.gov and a state list but not on LEIE is counted in the membership totals but not in those two cuts.
• A list membership is an administrative fact about the published list on the date queried, not a judgment about any party. Confirm any specific party's current status at the official source.

Six published lists. The U.S. exclusion registries — the HHS-OIG List of Excluded Individuals/Entities (LEIE), the GSA SAM.gov Exclusions registry, and the state Medicaid exclusion lists — are U.S. and state public records. The international lists are the EU Consolidated Financial Sanctions List (European Commission, CC-BY-4.0) and the UN Security Council Consolidated List (UN material, © United Nations). Each figure is sourced to its list's snapshot date, shown in the table above.

Sources: OIG LEIE (release 2026-05-08), SAM.gov Exclusions (snapshot 2026-06-18), state Medicaid exclusion lists (snapshot 2026-06-15), OFAC SDN (snapshot 2026-06-23), EU Consolidated List (snapshot 2026-06-05), UN Consolidated List (snapshot 2026-06-20). Aggregate counts only; no party named. Confirm current status at SAM.gov →