The International Sanctions Delisting Commission (“ISDC”) publishes research in an area where factual precision, source integrity and careful distinction between evidence and analysis are essential.
These Editorial Standards establish the principles applied to public sanctions review cases, institutional research, explanatory materials, news and other substantive ISDC publications.
Our Editorial Commitment
ISDC publications should allow a reader to understand not only what conclusion was reached, but what information supports it, where that information came from, and which parts of the publication constitute independent ISDC analysis.
Editorial independence is not limited to the final recommendation. It applies to the selection of sources, description of disputed facts, treatment of contrary evidence, language used in publication and the correction of the public record.
Six Standards We Apply
| Standard | Editorial Requirement |
|---|---|
| 01 — Accuracy | Material factual statements should be supported by identifiable evidence or appropriately attributed sources. |
| 02 — Attribution | Readers should be able to distinguish an official statement, a third-party allegation, documentary evidence and an ISDC conclusion. |
| 03 — Independence | Editorial conclusions must not be determined by a case applicant, contributor, external stakeholder or preferred outcome. |
| 04 — Proportionality | The strength of published language should reflect the strength and quality of the available evidence. |
| 05 — Context | Information should not be presented in a manner that materially changes its meaning by removing relevant context. |
| 06 — Correctability | Published work must remain capable of correction, clarification and updating when the record changes. |
The Three-Layer Editorial Model
ISDC seeks to maintain a visible distinction between three fundamentally different categories of information.
I. Official Record
This layer concerns what a competent authority, court, regulator or other official institution has stated, decided or recorded.
Examples may include:
- sanctions designation records;
- official statements of reasons;
- government notices and regulatory decisions;
- court judgments and procedural decisions;
- official amendments, renewals or delisting decisions.
When describing the official record, ISDC should avoid rewriting an authority’s position as though it were an independent factual finding of ISDC.
II. Evidence
The evidentiary layer concerns material relevant to assessing the continuing factual basis of a designation or other issue under review.
Evidence may support, contradict, qualify or provide context to an existing proposition.
The existence of a document does not by itself establish the truth of every statement contained within it. Evidentiary weight depends on provenance, reliability, relevance, corroboration and context.
III. ISDC Analysis
This layer contains the Commission’s independent assessment of the available record.
Analytical statements should be identifiable as analysis rather than presented as though they were official determinations or uncontested facts.
Official records tell us what was decided. Evidence helps establish what can presently be supported. Analysis explains what ISDC concludes from that record.
Source Hierarchy
Not all sources carry equal evidentiary or editorial weight. ISDC considers the nature of a source before relying upon it for a material proposition.
- Primary official material. Legislation, designation records, court judgments, regulatory notices and documents issued by competent authorities.
- Primary documentary evidence. Corporate records, contracts, filings, contemporaneous records, authenticated documents and other original materials.
- Independent authoritative sources. Established institutional, academic, professional or specialist sources with relevant expertise.
- Reputable secondary reporting. Reporting used with attention to sourcing, proximity to the events and independent corroboration.
- Interested-party material. Statements or documents provided by applicants, representatives, affected parties or other persons with a direct interest in the matter.
- Unverified or anonymous material. Information whose provenance cannot presently be established and which therefore requires particular caution.
This hierarchy is a guide to editorial assessment rather than an automatic rule of admissibility. A lower-ranked source may contain important verifiable evidence, while an official source may establish an authority’s position without independently establishing every underlying factual proposition.
Facts, Allegations and Findings
These terms should not be used interchangeably.
Fact
A proposition that ISDC considers sufficiently established for the purpose and context in which it is stated.
Allegation
A claim attributed to a person, authority, organization or source that should not be presented as independently established merely because it has been made publicly.
Finding
A reasoned conclusion reached by ISDC after assessment of the available information.
Where a material proposition remains contested or uncertain, the publication should communicate that uncertainty rather than resolving it through editorial wording alone.
Language and Evidentiary Confidence
Editorial language should reflect the degree of confidence justified by the underlying record.
| Formulation | Editorial Meaning |
|---|---|
| “The official record states…” | ISDC is describing an official position without independently adopting the proposition as fact. |
| “The available evidence indicates…” | The evidence supports the proposition, while the wording preserves appropriate analytical caution. |
| “ISDC finds…” | ISDC has reached an affirmative analytical conclusion on the available record. |
| “ISDC has not established…” | The available material is insufficient to support the proposition to the required analytical level. |
| “The record remains inconclusive…” | Competing or incomplete evidence prevents a reliable conclusion. |
Neutrality Does Not Mean Artificial Balance
Editorial neutrality requires fair treatment of relevant evidence. It does not require ISDC to give equal weight to claims that are supported by materially different levels of evidence.
A well-supported proposition and an unsupported assertion should not be presented as equally established merely to create the appearance of balance.
At the same time, material evidence inconsistent with an anticipated or preferred conclusion should not be omitted because it complicates the analysis.
Adverse and Contested Information
Sanctions-related research may involve allegations of serious misconduct, political exposure, commercial relationships, ownership, control or other potentially adverse information.
When publishing such material, ISDC should consider:
- whether the information is relevant to the review;
- whether the source is identifiable and appropriately described;
- whether the allegation has been independently established;
- whether material contrary evidence exists;
- whether the language accurately reflects the status of the claim;
- whether publication is proportionate to its evidentiary significance.
Right of Response
Where practicable and editorially appropriate, ISDC may seek comment or clarification from a person or organization directly affected by a material contested assertion.
A request for comment does not grant editorial control over the publication, and the absence of a response does not by itself establish the truth of the underlying assertion.
Relevant responses received after publication may be considered for an update, clarification or further review.
Case Applicants and Interested Parties
Information supplied by an applicant, legal representative, affected person or other interested party may be important to a review, but its origin should be considered when assessing evidentiary weight.
Submission by an interested party does not make information unreliable. Equally, submission in documentary form does not automatically make it independently verified.
Where appropriate, ISDC should seek corroboration from independent or primary sources.
What ISDC Does Not Edit for
Editorial decisions should not be made for the purpose of:
- producing a predetermined sanctions outcome;
- protecting a case applicant from relevant adverse evidence;
- strengthening an allegation beyond what the evidence supports;
- aligning a publication with a political position;
- creating artificial certainty where the record is incomplete;
- avoiding a justified conclusion because it may be controversial.
Headlines, Summaries and Case Titles
Headlines and summaries should accurately represent the substance of the underlying publication.
ISDC should avoid sensational, accusatory or promotional language that materially exceeds the findings contained in the full analysis.
A reader who sees only a title or summary should not receive a materially different impression from a reader who examines the complete record.
Quotations and Documents
Quotations should preserve the material meaning of the source and should not omit surrounding context where doing so would materially alter the reader’s understanding.
Extracts from documents should be attributed where appropriate. Translations, summaries and editorial descriptions should not be presented as verbatim source text.
Anonymous and Confidential Sources
ISDC generally favors identifiable and reviewable sources.
Information from a confidential or non-public source may nevertheless be relevant where there is a legitimate reason for confidentiality and the information can be assessed responsibly.
Reliance on such material should take account of:
- the source’s proximity to the information;
- the reason confidentiality is requested;
- the possibility of bias or conflicting interests;
- available corroborating evidence;
- the significance of the proposition being supported.
Confidentiality does not remove the need for editorial scrutiny.
Use of Automated and AI-Assisted Tools
ISDC may use technological tools to support administrative, research, organizational, translation, search or analytical workflows.
Automated output should not be treated as an authoritative source merely because it has been generated by a technical system.
Material factual propositions, citations and substantive analytical conclusions intended for publication should remain subject to appropriate human review and source verification.
Technology may assist the review process. Responsibility for published institutional conclusions remains human.
Editorial Independence and Conflicts
A person involved in substantive preparation or review of a publication should disclose a material personal, professional or financial interest that could reasonably call their independence into question.
Depending on the circumstances, a conflict may require disclosure, additional independent review, limitation of involvement or recusal from the relevant editorial decision.
Corrections After Publication
Publication is not the end of editorial responsibility.
Material factual errors should be assessed under the ISDC Corrections Policy. New evidence or subsequent official developments may require an update even where the original publication was accurate when issued.
Analytical conclusions may also be reconsidered where the evidentiary basis materially changes.
Pre-Publication Review
Before substantive material is published, the editorial review should, where applicable, consider the following questions:
- Are the material factual propositions supported by identifiable sources?
- Is official information clearly distinguished from independent evidence?
- Are allegations attributed rather than silently converted into facts?
- Has materially contrary evidence been considered?
- Does the language reflect the actual strength of the evidence?
- Are quotations, dates, names and material references accurate?
- Are interested-party submissions appropriately identified and assessed?
- Is the ISDC analytical conclusion clearly distinguishable from the underlying record?
- Would the headline or summary remain fair if read without the full publication?
- Is there any material conflict requiring disclosure or independent review?
The Publication Test
Could an informed reader identify the source of the material claim, understand the limits of the evidence, distinguish fact from analysis, and see how ISDC reached its conclusion?
If the answer is no, the publication may require further sourcing, verification, qualification or editorial review before release.
Editorial Responsibility
These standards are intended to support consistent institutional practice while preserving the judgment required for complex sanctions review.
They should be read together with ISDC’s Review Standards, Evidence Standards, Corrections Policy, Conflict of Interest Policy and other applicable institutional documents.
Editorial Principle
The credibility of sanctions review depends not only on the conclusion reached, but on the discipline of the process used to reach it.
Attribute what is alleged. Verify what can be verified. State uncertainty where uncertainty remains. Separate evidence from judgment. Correct the record when the record requires it.