U.S. Government Denied Party List
December 21, 2010
The U.S. Government has finally consolidated denied party lists at http://www.export.gov/ecr/eg_main_023148.asp from the Bureau of Industry and Security (BIS), Office of Foreign Asset Controls (OFAC), and the State Department. In the past, exporters had to either purchase a software service that consolidated the lists, or check web pages individually. The new single list can be downloaded into Excel or ASCII. The list is generally current, but updates to the list are not made as quickly as the Federal Register notices.
The list contains:
* Department of Commerce – Bureau of Industry and Security
Denied Persons List – Individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited.
Unverified List – End-users who BIS has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction.
Entity List – Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.
* Department of State – Bureau of International Security and Non-proliferation
Nonproliferation Sanctions – Parties that have been sanctioned under various statutes. The linked webpage is updated as appropriate, but the Federal Register is the only official and complete listing of nonproliferation sanctions determinations.
* Department of State – Directorate of Defense Trade Controls
AECA Debarred List – Entities and individuals prohibited from participating directly or indirectly in the export of defense articles, including technical data and defense services. Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to “statutory debarment” or persons established to have violated the AECA in an administrative proceeding and subject to “administrative debarment.”
* Department of the Treasury – Office of Foreign Assets Control
Specially Designated Nationals List – Parties who may be prohibited from export transactions based on OFAC’s regulations. The EAR require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes “SDGT”, “SDT”, “FTO”, “IRAQ2” or “NPWMD”.”
BDP International has developed a web-based application that can be accessed anywhere in the world allowing a person to query the content and be provided results immediately giving the ability to obtain additional details or stop the process.
The web-based application is updated with content from all of the lists that are published around the world, not just the US lists, therefore when seeking a solution that is truly global in content please do not hesitate to contact the BDP Regulatory Team for your compliance needs.
Having access to the content is only one of the challenges that a company will need to review when setting up their tasks when managing all of the entities that are listed in the consolidated lists. The next logical step is the set-up of the system logic that will automate the process.
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