ICIJ Offshore Leaks Database — License Notice

Entity pages on this site that match a node in the ICIJ Offshore Leaks Database render the matched offshore-structure data natively, in-page, rather than linking out to the ICIJ site for that detail. This notice explains the license the underlying data is published under, what it requires of us as a redistributor, and what it does — and does not — mean for the rest of this site's content.

The license

The ICIJ Offshore Leaks Database is published directly by ICIJ under two licenses that apply together:

• The database itself: Open Database License (ODbL) 1.0. ODbL is a share-alike license for databases (as distinct from their contents). It permits copying, distributing, and adapting the database, including for commercial use, provided attribution is given and — critically — that any Derivative Database produced from it is offered under the same ODbL terms (ODbL §4.4, the share-alike clause).
• The contents of the database: Creative Commons Attribution-ShareAlike 4.0 (CC BY-SA 4.0). This covers the individual facts and records within the database (as distinct from the database structure), again requiring attribution and share-alike redistribution of adaptations.
• No NonCommercial clause. Sourced directly from ICIJ's own published terms at offshoreleaks.icij.org, this license carries no CC BY-NC restriction. (A CC BY-NC wrapper appears in some third-party redistributions of ICIJ data, such as certain OEM/vendor catalogs — that is the redistributor's own relicensing choice, not a term ICIJ itself imposes. proofaml.com sources ICIJ data directly from ICIJ, so we inherit ICIJ's own ODbL/CC BY-SA terms, not any third party's narrower wrapper.)

Full text: ODbL 1.0 · CC BY-SA 4.0.

What this means for proofaml.com

We host a derivative of the ICIJ database, with attribution, as ODbL and CC BY-SA require. Every page carrying ICIJ-sourced content — entity pages with a matched "Offshore structures (ICIJ Offshore Leaks)" block — displays attribution to the International Consortium of Investigative Journalists and a link to the ICIJ Offshore Leaks Database, and this notice is linked from every such block.

Only the matched cross-reference is republished, never the raw database. We ingest ICIJ's full bulk export at build time, but we do not redistribute it. What is vendored into and served from this site is a small, derived slice: for each of our existing sanctioned or PEP entities that name-and-country-matches an ICIJ node, the specific offshore entities, roles, and dates connected to that match. This is a "Produced Work" under ODbL §4.4 rather than the database itself — the raw ~600 MB, multi-million-row ICIJ corpus is never vendored, published, or made available for bulk download from proofaml.com.

ICIJ-sourced fields stay under ODbL / CC BY-SA even as hosted here. Per ODbL §4.4, when a Derivative Database (or, as here, a Produced Work drawn from one) is made available to the public, the ICIJ-sourced facts within it — offshore entity names, jurisdictions, incorporation and dissolution dates, roles, and source-leak labels (Panama Papers, Paradise Papers, Pandora Papers, Bahamas Leaks, Offshore Leaks) — remain governed by ODbL/CC BY-SA, regardless of the fact that they are surfaced through proofaml.com's own page templates. We do not represent ICIJ-sourced fields as proprietary proofaml.com data.

ICIJ-sourced fields are kept visibly separate from proofaml-original content. The offshore-structures block on an entity page is a clearly delineated section (its own heading, its own attribution line, its own license notice linking here) rather than data blended indistinguishably into proofaml.com's own sanctions/PEP record. Any proofaml-original analysis or annotation we might add alongside ICIJ-sourced fields in the future is intended to stay separable from — and not represented as part of — the ICIJ-licensed data itself, consistent with ODbL §4.4's share-alike scope applying to the ICIJ-sourced material.

Standing legal-review flag. A full legal review of ODbL §4.4 compliance for this Produced-Work redistribution is outstanding — tracked as [VERIFY: ODbL derivative-database compliance for native ICIJ entity-page rendering, real legal review] (see management/work/decisions/019-icij-native-hosting-supersedes-018.md residual risk (a) and engineering/work/adr/048-icij-offshore-leaks-enrichment.md §3). We proceed on the Produced-Work-scoping default described above in the meantime, per this repo's no-human-gates policy; this is a to-do for the next compliance sweep, not a condition on publishing.

Not evidence of wrongdoing

Appearing in the ICIJ Offshore Leaks Database — and therefore appearing in a matched cross-reference on this site — is not evidence of wrongdoing. Offshore structures are frequently used for entirely lawful purposes (tax planning, asset holding, corporate structuring), and identities require independent confirmation: ICIJ's own name-collision caveat applies, and every cross-reference on this site carries a visible match-confidence indicator (medium/name+country, or low/name-only) precisely because a name-based match is not a confirmed identity. Nothing in an ICIJ cross-reference is, or should be read as, a sanctions designation, a PEP designation, or an allegation of any kind.

Frozen snapshot

ICIJ's Offshore Leaks content has been static since 2022-05-03 (the final Pandora Papers phase). Later file timestamps on ICIJ's own infrastructure reflect reconciliation/hosting refreshes, not new leak content. proofaml.com labels this dataset as a frozen snapshot wherever it is surfaced, and does not represent it as a live feed.