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

http://www.bis.doc.gov/index.php/the-denied-persons-list

• Entity List – Export Administration Regulations

            http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list

• Unverified List – Export Administration Regulations

http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/unverified-list

• Military End User List

https://www.bis.doc.gov/index.php/documents/regulations-docs/2343-part-744-control-policy-end-user-and-end-use-based-2/file

• Debarment List – International Traffic In Arms Regulations

https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&sys_id=c22d1833dbb8d300d0a370131f9619f0

• 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

https://www.state.gov/key-topics-bureau-of-international-security-and-nonproliferation/nonproliferation-sanctions/

• Specially Designated Nationals List – Foreign Asset Controls Regulations

            http://www.treasury.gov/ofac/downloads/sdnlist.txt

–     Sectoral Sanctions Identifications (SSI) List – Foreign Asset Controls Regulations

https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/ssi_list.aspx

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.