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 […]
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: 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: 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 […]
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 […]
Question: I would like to ask if any members how they handle when checking a person or companies name against all the denied listings and there is a hit but maybe not the exact name. How do you approach this new potential customer and ask if they are related in any manner? Do you have […]
Question: I would like to ask if any members how they handle when checking a person or companies name against all the denied listings and there is a hit but maybe not the exact name. How do you approach this new potential customer and ask if they are related in any manner? Do you have […]
Question: When conducting denied party screening, I often find false hits against Treasury’s Specially Designated Nationals (SDN) list. Typically I’ll have a customer in the USA and currently only know the first and last name. The potential match from the SDN list will be in another country where the same name exists with the addition […]
Question: Just curious if importers are screening their vendor base on the variouslists such as denied parties and entity List. Obviously from the export sidethis is common practice but just wondering if importer’s are doing thesescreenings before they purchase from vendors
Question: How do companies handle export requalification of customers? As far as DPL screening, each of our customers are screened each time a shipment is sent to them. Clearly that is not extensive enough. I know we have to have LOA’s signed periodically and we really should rescreen the principle partner names to make sure […]
Question:We currently screen against the various Denied/Restricted Party Lists all new hire employees before hiring them. However, we are being encouraged to screen our active employees on a continuous basis. Do any members screen their employees on a routine basis, other than before hiring, and if so, how often and approximately how many employees does […]
Question:This question regards the subject of customer “walk ins” at US retail level sales outlets for “cash & carry” transactions. These transactions can be related to any retail business selling across the counter to the public. Unless the retail outlet has “reason to know” the goods are being purchased for subsequent exportation, what responsibility/liability does […]
