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Supply Chain : Compliance Corner Use the Web for denied party lists By Tom COOK, American River International Best practices, due diligence and reasonable care provisions require our taking compliance responsibilities seriously. The following five Web sites are good references for referencing denied party listings: Denied persons lists www.bis.doc.gov/dpl/dpl.txt This is a list of 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 www.bis.doc.gov/enforcement/unverifiedlist/unverified_parties.html This is a list of parties where BIS has been unable to verify the end-user 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. Entities list www.bis.doc.gov/entities/default.htm Entities List is a list of parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations. The list specifies the license requirements that apply to each listed party. These license requirements are in addition to any license requirements imposed on the transaction by other provisions of the Export Administration Regulations. Office of Foreign Asset Controls Specially Designated Nationals list www.treas.gov/offices/enforcement/ofac/sdn/ This is a list compiled by the Treasury Department, Office of Foreign Assets Control (OFAC). OFAC’s regulations may prohibit a transaction if a party on this list is involved. In addition, the Export Administration Regulations require a license for exports or re exports to any party in any entry on this list that contains any of the suffixes “SDGT”, “SDT”, “FTO”, “IRAQ2” or “NPWMD.” Debarred list www.pmddtc.state.gov/compliance/debar.html The debarred list is compiled by the State Department of parties who are barred by §127.7 of the International Traffic in Arms Regulations (ITAR) (22 CFR §127.7) from participating directly or indirectly in the export of defense articles, including technical data or in the furnishing of defense services for which a license or approval is required by the ITAR. In any export compliance program it is the responsibility of the exporter and their service providers and carriers to check these lists prior to moving the transaction along. Failure to check these lists can cause a consequential fine or penalty and possible loss of export privileges. Importers also have a responsibility to check the lists, prior to engaging in an inbound purchase or shipment.	In This Issue Up Front News, Trends & Analysis News Trade Tools: Missing money Capitol Watch: Focus on job creation Supply Chain Chris Steele: Why you might be buying industrial real estate soon Compliance Corner: Use the Web for denied party lists Tech Trends: From open source to terminal visibility Product Review: Trucking drayage and chassis management software Commentary David Bennett: Real signs of trouble Gateway Glance New England Southern California The Port Community Bumpy Ride: Rebuilding PNW containerized exports Southwest Intermodal: Can intermodal incentives show the way? The Shipping Environment: Engaging in the community, slow steaming, and new green products Oceans are making waves Casualties The Big Texas spill leads off this month’s rundown Final Say Top 25 TIGER projects
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Supply Chain : Compliance Corner