A key component to every company’s export compliance program should be screening of the U.S. government export sanctioned lists prior to shipment. Companies may choose to screen the lists prior to accepting an order, but that does not negate their responsibility to screen prior to shipment as well as parties may have been added after the first check. Lists that should be screened include the following:
- Denied Persons List – Export Administration Regulations
- Entity List – Export Administration Regulations
- Unverified List – Export Administration Regulations
- Military End User List
- Debarment List – International Traffic In Arms Regulations
- Countering America’s Adversaries Through Sanctions Act- Department of State https://www.state.gov/t/isn/caatsa/275116.htm
- Non-Proliferation Sanctions List – International Traffic In Arms Regulations
- Specially Designated Nationals List – Foreign Asset Controls Regulations
– Sectoral Sanctions Identifications (SSI) List – Foreign Asset Controls Regulations
All parties to the transaction should be screened, and if any positive results are found, the ECO/Empowered Official should be contacted to see if the transaction/sale must be cancelled.
The U.S. Government has consolidated the required lists into one list= the Consolidated Screening List. https://www.trade.gov/consolidated-screening-list
Should you have any questions on the above lists and the screening requirement, or any questions/concerns on results obtained, please contact our office.
This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.