Treasury Offers New Ways to Search for Export Compliance Risks

In an effort to make it easier to monitor sanctions programs, the Treasury Department has consolidated several sanctions lists.  This consolidation should make it easier to search to ensure compliance, whether you are searching on line or using a computer program to automatically research your customers.

The Treasury Department office with jurisdiction over export programs is the Office of Foreign Asset Control (OFAC).

OFAC has a list of Specially Designated Nationals (SDNs) as well as other (non-SDN) sanctions lists.  OFAC  is now offering all of its non-SDN sanctions lists in a consolidated set of data files called the Consolidated Sanctions List.  This consolidated list will include the following:

  • Non-SDN Palestinian Legislative Council List
  • Part 561 List
  • Non-SDN Iran Sanctions Act List
  • Foreign Sanctions Evaders List
  • Sectoral Sanctions Identifications List

OFAC announced that it plans to discontinue some of these lists as separate lists, so they will only be available as part of the consolidated list.

Persons seeking to check whether there are OFAC sanctions that might apply to their transaction should be sure to check their export business partners (by personal name and company name) against the Specially Designated Nationals List and the Consolidated Sanctions List

One can also use the Sanctions List Search which consolidates both lists into a single searchable database. This tool is useful because it can automatically search for names that are close (bot not exact matches) and can be set to find matches with different levels of confidence (which will then be reviewed by a human to assess whether they actually match).

Exporters should also check the details of their transaction (including destination country) against the Sanctions Programs and Country Information page, which list sanctions programs based on country and on certain other criteria.

 

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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