Denied Parties

Questions and answers about Denied Parties

  • RPS MATCH

    Question: Our company subscribes to and uses automated screening software.  I had a match for the first time today because the company I screened was on a list called the Iowa Public Employees’ Retirement System’s Iran/Sudan Prohibited Companies Lists. Does anyone know if this list is a concern for exporters?  Any advice on how should […]

  • COMPANY ON BIS / OFAC LISTINGS

    Question: I would the opinion of the Export trade community on the below situation to check my sanity / interpretation of regulation. Company A in on the Entity List and OFAC.   They own machines that are enumerated on the CCL.My company feels that if a “unrelated” service Company B purchase parts for these machines owned by company […]

  • ANSWER TO QUESTION ON CRIMEA EXCLUSIONS

    Question: I am hoping the membership can shed some light here. The new GL-4 which allows for exportation and reexportation of medicines to Crimea has a list of excluded medicines. This list includes ‘bioactive peptides’. I have found a definition of ‘bioactive peptides’ in the FAQ section of the Iran sanctions program. Can anyone tell […]

  • DENIED PARTY SCREENING

    Question: We are creating an in-house denied party screening program.  IT is proposing to screen only the entity name and country at the initial level.  Anything flagged would go under a manual review. My question is do we need to screen addresses at the initial level too?  I thought there was a list of denied […]

  • DENIED PARTY SCREENING OF BANKS

    Question: My company uses a program to perform denied/restricted party screening of all its customers, vendors/suppliers, and employees.  We are now trying to decide if we should expand our screening program to include all of the banks we do business with.  What is everyone else doing?  I’m not sure if the U.S. government would consider […]

  • QUESTION ON RESTRICTED PARTY SCREENING LISTS

      Question: We as a company are in the process of implementing a global import export compliance program. Parts of our company have already a tool to do restricted party screening (blacklist screening).   As we are going to use the tool globally which lists are available to screen against ? Is there a source […]

  • PROCESS FOR DENIED PARTIES “HIT”

      Question: I can’t be the first or only ICPA member to deal with this situation so I’d like any advice the membership cares to provide. Scenario: An existing customer is running our software (not ITAR but either EAR99 or 5D002). We screened the customer and their contacts against the various denied party lists when […]

  • Denied Party Screening Liability for U.S. Subsidiaries

      QUESTION: Are U.S. subsidiaries subject to OFAC regulations for products produced in   their own regions and sold to other countries (outside the U.S.)?  I   understand the U.S. Subsidiaries are considered “US Persons” and would be   liable for U.S. produced product but I am requesting clarification if U.S.   export law also […]

  • QUESTION ON DPL SCREENING FOR DOMESTIC ORDERS

      Question:   We are in the process of implementing a new ERP system and are going to automate our export screening.  Currently we are manually screening international orders.  When we automate, should I request ALL orders to be screened – international and domestic?  Licenses are not required for our product and it falls into […]

  • QUESTION ON DENIED PARTIES REVIEW

      Question:   Has anyone setup their own internal Denied Parties Review using the nine or so list’s that are available?   My company currently does not do Denied Parties Review but I now have approval to get this setup.  I have reviewed some of the companies that provide this search for a fee and […]

  • Visitor Screening

      Question:   I have searched the database for visitor screening and have a few questions. We are an international company, but my division consists of repackaging.  We do not have high technology and we do not sponsor visa foreign visits.  We do have visitor controls where, ID checked, temporary badge issued, recordkeeping of visit/photo […]