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 […]
QUESTION: When you do get a hit from screening for denied parties does anyone in the membership have a boiler plate request for information to confirm the hit and the person being screened are not one in the same? I have been getting hits here and there and when I ask our sales rep to […]
QUESTION: The company is organized into separate business units. Some business unit corporate/headquarters are in the United States, but most are in Europe. This question is geared towards the US corporate office. In performing a screening for potential new business outside of the United States it was found that the purchaser is listed on […]
QUESTION: Would any of the members have a basic Denied Party Screening presentation to share ? Very basic and high level would be fine. =========== Answer: Hello, please find attached a basic presentation on denied party screening. http://www.icpainc.org/wp-content/uploads/2014/10/20160928_N.-Richards-Bentley_EU_Export_Controls_Conference_Screening_Speech_FINAL.pdf ========== We don’t have a lot of export volume, so I like to keep it short. This […]
Question: One of our European affiliates has a customer located in Spain that shares the same name/nationality as a person on Interpol’s list. The Interpol information indicates the person is wanted in the Dominican Republic. We confirmed this person is not shown on either the US or UK “Consolidated Lists” as a denied party, […]
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 […]
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 […]
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 […]
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 […]
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 […]
