The adoption of the Affiliates Rule will mean that the Consolidated Screening List (CSL) will no longer comprise an exhaustive listing of foreign entities subject to Entity List license requirements. The CSL, for purposes of the Entity List, will only include the entities listed on the Entity List and will not reflect these additional foreign affiliates of listed entities that are owned 50 percent or more by one or more listed entities. Persons should screen proposed transactions against the CSL and separately screen for purposes of the Affiliates Rule.
If you are using a screening service (e.g. Visual Compliance) check with your provider to ascertain whether their screening takes the Affiliate Rule into account and determine what other steps are necessary in your company’s screening procedure.
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