Question: My company produces mining equipment. Should we keep track of what the customers do with the ore they quarry with our machines. If we a see risk that the customer might sell the ore to a sanctioned country, what action should we take? Answer 1: You don’t have to make an active program that […]
Question: Viktor Feliksovich Vekselberg is an OFAC SDN. A potential new vendor was screened and was blocked for UBO. The SDN is a 43% owner of the potential new vendor. What risks should be considered with whether or not to do business with the potential vendor for any of our global companies? Answer 1: A […]
Question: From the various feedback I’ve received relating to SPL screening, I’m hopeful the membership can provide further guidance. We have a lot of false positives due to street name matches. The block is not applicable to the business partner. What is available to enable the business partner to no longer be blocked by the […]
Question: I joined a company where we subscribed to ALL lists from a major trade compliance provider. I plan to either disregard certain lists, i.e. SMEL, which doesn’t apply to us, or to stop subscribing to certain lists. While that may work to resolve the sheer number of blocks every day, my other issue is […]
Question: Hello, We are a food manufacturer who screens all parties – – to ALL lists through Descartes. (Yes, all. I used to work in A&D, and we did not subscribe to ALL the lists.) We manufacture and sell direct to food service distributors, restaurants, and the like. I am working with Legal to discontinue […]
Question: Can restricted-party screening software receive the name of a foreign company, then determine the owners of the company, and then run the owners’ names through government watch lists? Answer 1: No. You need a separate service if you want to outsource ownership analysis. Be ready – this is an expensive service, and only the […]
Question: We are looking to do business with a Company in the UAE. After completing restricted party screening, we received country notes indicating high risk for financial action task force. Is this risk associated with UAE a reason to not move forward with the Customer? Answer 1: A hit on the UAE for financial concerns […]
Question: I recently joined a company for a new compliance role. A major concern I have is there is no screening process of customers other than credit checks. I continue to push to the higher ups on the importance of screening to help facilitate the spend for a screening tool, but the feedback I receive […]
Question: Hello Community, While reviewing a hit to the Sanctioned Party List – FCPA, we found the entity on the SPL to be an exact match of our business partner. The reason (violation) for the entity to be on the SPL – FCPA list, does not relate to our business. If our business is not […]
Question: Hi, When OFAC sends notifications about SDN list, will they provide all locations related to the blocked company meaning if Company A has locations in Germany and China, will they list both countries in the rule? Answer 1: OFAC will not provide all locations of a blocked company, or even the names of all […]
Question: Is it required to screen all employees of a customer/vendor who may come in contact with our company? For instance, the person who sends us the PO for a well-known global customer for EAR99 goods versus screening the well-known global customer name and address for said company? We have outside counsel directing to screening […]
Question: Is there a questionnaire anyone has available for screening customers and suppliers that is available anywhere one could use for manually screening new and potential customers/suppliers? We currently don’t have a software in place that does this for us and guidance will be much appreciated until we get one set up. Thank you in […]
