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 […]
QUESTION: As a wholly owned subsidiary of a Japanese company located in the U.S, we import and export components that are supplied by our parent company in Japan. These components are manufactured by various companies in other countries such as Japan, China, Taiwan, etc. We do not always know who the actual manufacturer is, we […]
QUESTION: Is denied party screening required when shipping firearms domestically within the United States? ************** Answers: Denied party screening is NOT a legal requirement. The legal requirement is to “Know Your Customer” and not to do business with bad people or in bad places. However, it is difficult to know if someone is a “bad” […]
QUESTION: I work for medical device company where the company plans on delivering the medical devices direct to patients. My question is in regards to denied party screening. I have heard during BIS meetings that at the retail level the purchase should be screened. At present our agreements with retailers and distributors with export control […]
QUESTION: Does anyone from the trade community screen ocean vessels and carriers? Our products are not controlled by any jurisdiction, and these are exported to non-sanctioned destinations. *********** Answers: It is a good practice to screen the ocean vessel carriers. *********** If you are not booking the cargo, you should screen vessels. Conference carriers are […]
QUESTION: We have different, related companies registered under the laws of a few different countries that either manufacture and sell their own product or distribute our US made product for us. These entities, inclusive of our US registered company, are all part of a larger US corporation. Our US registered company conducts screenings on […]
QUESTION: Is it possible for a company to be penalized for doing business with a denied party by more than one government agency, such as BIS and OFAC and State Department? (Can one company be fined from multiple agencies for the same infraction? Ex: I send something to North Korea. BIS fines me, OFAC fines […]
QUESTION: I am interested to know what best practice is regarding DPL screenings. 1) How often should we conduct the screening? 2) Some members of my procurement team advise that if we screen every transaction at time of shipment it slows the shipment down. If this is an automated process that takes merely seconds […]
