Are your current restricted parties screening procedures adequate? A recent settlement by JP Morgan Chase should be sufficient motivation for every company to scrutinize their export policies and procedures and sanctioned parties screening process. On October 5th of this year, JP Morgan Chase reached a 5.26 million-dollar settlement with the Office of Foreign Assets Control for sanctioned party’s violations between 2008 and 2012. If a company with resources as vast as JP Morgan can have gaps in their screening, what red flags might an audit of your policy and procedures reveal? While 5.26 million dollars is a pittance for a large financial institution, a similar finding could have a dire financial impact on a smaller company and cause embarrassment and a loss of public trust.
Companies should diligently screen all persons and parties involved in export transactions against the Denied Persons List, Entity List, Unverified List, Debarment List, Sanctioned Parties List, Nonproliferation Sanctions List, Specially Designated National List and Sectoral Sanctions Identifications List. Should you have questions or concerns regarding your restricted parties screening or a potential export transaction please contact our office and we can help you avoid a potentially costly mistake.
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.
