QUESTION: Does anyone have a general screening SOP for Denied Parties/Persons for US Export Transactions they can share =========== Answer: The thing with your question is that yes, there is usually a high level “policy” in your export compliance manual or wherever, saying we will screen, including who and when. But this is usually high level. […]
QUESTION: Looking for measures or recommendations from the ICPA community regarding DPS and employees (existing or soon to be) In some cases, companies perform denied party screening prior to onboarding any new employees and as part of background check. Employment and state laws sometimes require an individual to grant consent before screening takes place and […]
QUESTION: How many sanction party lists do members think our compliance software should scan to stay compliant? Example: 5 lists, 20 or 50. What makes the largest difference whether it’s 5 or 50? Thank you. %%%%%%%%%% ANSWERS: There’s not enough information below to answer that question. You should be asking yourself: What is our export […]
QUESTION: Regarding Denied Party Screening: is DPS required for both International AND Domestic purchases for E-Commerce and non-E-Commerce items? ———————- ANSWERS: Not required. No regulation on DPS screening. But it’s highly recommended. —————————- Denied party screening is not a requirement. Not doing business with a denied party is the requirement. Who you screen, what you […]
QUESTION: We are a US based company with facilities in Canada and GB. As the parent company located in the USA, we run DPS on all visitors to our US locations. Should we be running DPS on visitors to non-US facilities? Specific references to regulations or rulings to backup answers would be appreciated. ========== […]
QUESTION: I am working to create an at-a-glance document to help explain internally to our global stakeholders who all the U.S. government entities are that issue the denied/restricted/sanction lists, what their reach is, and what the implication of the lists are. Probably more than the one page high level document that I envision, but I […]
UESTION: Regarding Denied Party Screening: is DPS required for both International AND Domestic purchases for E-Commerce and non-E-Commerce items? %%%%%%%%%% ANSWERS: Not required. No regulation on DPS screening. But it’s highly recommended. %%%%%%%%%% Denied party screening is not a requirement. Not doing business with a denied party is the requirement. Who you screen, what you […]
QUESTION: We are a US based company with facilities in Canada and GB. As the parent company located in the USA, we run DPS on all visitors to our US locations. Should we be running DPS on visitors to non-US facilities? Specific references to regulations or rulings to backup answers would be appreciated. ========== […]
QUESTION: How do other companies maintain that their 3rd party companies screen and vet their customers, suppliers and vendors properly? In other words how far do you go with a 3rd party agent? Do you feel it’s necessary to screen and vet an international bank that will receive wire transfers as well ? ========== Answer: YES!!!
QUESTION: What is the risk for not screening domestic customers and vendors? I know OFAC has a lot of entities in the US, but what is our risk if all the payments we send or receive go through our bank. Don’t banks have their own screening in place that would stop transactions sent or received […]
QUESTION: We are evaluating our search criteria for denied party screenings and are curious if other members screen addresses along with names (company and contact names)? We deliver almost all of our exports electronically, so we don’t know if our exports are delivered to the address we screen. Most of the false hits we review […]
QUESTION: What are the penalties for conducting business with a denied party on a NON-U.S. restricted party list? Are there any examples? I am writing the policy for our restricted party screening and in the regulations it is clear that U.S. business can face penalties or denial of export privileges if they conduct business with […]
