We release OpenSanctions Pairs, the first large-scale public benchmark for entity matching on sanctions and OSINT data. The dataset includes 755,540 expert-labeled pairs over 1 million entities, aggregated from 293 source datasets across 45 jurisdictions. It captures real-world diversity in compliance data, spanning multiple languages and writing systems (e.g., Latin, Cyrillic, Arabic), inconsistent structure, and time-varying provenance, and is substantially more heterogeneous than prior entity matching benchmarks. As baselines, we evaluate the production rule-based matcher (nomenklatura RegressionV1) alongside open- and closed-source LLMs in both zero- and few-shot settings, each tested with and without MIPROv2 prompt optimization to control for prompt sensitivity. The rule-based baseline reaches 91.3\% F1; GPT-4o achieves the best result at 99.0\% F1, and a locally deployable open-source model (DeepSeek-R1-Distill-Qwen-14B) achieves 98.2\% F1. The rule-based baseline and LLMs fail in complementary ways: rules over-match, while LLMs struggle with cross-script transliteration. These results suggest that pairwise matching performance is approaching a practical ceiling and shift attention toward pipeline components such as blocking, clustering, and uncertainty-aware review.

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