So far in 2020, the restricted parties lists published by the Bureau of Industry and Security (BIS), OFAC and the State Department have been updated more than 80 times. With updates occurring on an almost daily basis, it is important to check all parties involved in an export transaction against the restricted parties list at the time the order is placed and also at the time of shipment as a party that cleared screening at the time of order may have been sanctioned between order and shipment. This includes parties listed as licensed parties who, while screened during license review, may have been sanctioned following license approval.
Sanction lists are:
Denied Persons List – Export Administration Regulations
Entity List – Export Administration Regulations
Unverified List – Export Administration Regulations
Debarment List – International Traffic in Arms Regulations
Countering America’s Adversaries Through Sanctions Act- Department of State
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
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.