Governments about the world want to ensure
that organizations know their business partners. Observing these vast
commercial networks in order to publicly designate criminal and terrorist groups
takes the vast resources of national governments and international
organizations such as the United Nations and the World Bank.
Authorized individuals, vessels, companies,
entities and charities are published on sanctions lists and restricted or denied parties lists.
These lists often identify the name, address, alias’ used and sometimes
personal information such as date of birth. Companies, insurance and financial
industry partners utilize these various lists as part of their trade compliance
operation. The restricted lists are compared or screened against an
organization’s business partners, suppliers, vendors, and customers to identify
potential risks of inadvertently conducting business with debarred parties. The
terms: restricted; sanctioned; denied; and debarred are often used
interchangeably when speaking of these many various lists.
Due to trade compliance desires, the
partners involved in all cross-border trade transactions must experience
screening. Any parties or transactions flagged by an active sanction list will
need to be investigated further. During the additional due diligence process
organizations may find that a transaction partner is subject to a strict export
ban, license requirement, or further evaluation of the end-use.
All companies are required to have a
process to identify and manage red flags arising out of the due assiduousness
process and companies exporting controlled products and technology are required
to have sophisticated Know Your Customer (KYC) processes.
How
to avoid Restricted Parties Screening
All list
publishing organizations Denied or
Restricted Parties from a sanctions list when necessary to meet their Global Trade Management and foreign
policy objectives. The names and addresses of additions and removals are
regularly updated in the sanctions list as well as the denied or restricted
party lists. These lists are made available by the government in three ways: an
open API, downloadable CSV, and a manual search engine. A Programming
interface, specifically, empowers firms to include information into a dashboard
for ongoing exchange observing. Others may collaborate with third-party service
providers to create lists-incorporating tools.
The KYC
guidance, which provides specific controls for identifying and avoiding
restricted individuals, must be understood by businesses.
A KYC
program's most important considerations include:
Learn about
"Red Flag Indicators" that indicate potential wrongdoing, such as:
Cash
payments for big-ticket items with no clear purpose Freight forwarders listed
as the final destination with little or no business history Screen all parties
involved in a transaction—including freight forwarders, consignees, etc.—
against the sanctions list and the party lists that are Denied
Parties Screening. If you think an export transaction might be against
the law, tell your director of internal trade compliance. Always look for red
flags and let management know if there are any irregularities that affect trade
compliance.
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