Match Found In Denied Party Screening Process.
What to do when you find a positive match in Restricted and Denied Party Screening? The process can bring either one of the following results:
- No match is found: Depending on the screening method selected, no match to the screened entity is found. Typically, if the screening criteria is “exact name or address match” and if no match is found then it is advisable to repeat the screening with a different selection criterion, such as “sounds similar” or “phonetic match”. Alternatively, words found in the name of the entity can be separately searched.
- Partial matches are found: It should be ensured that screened entity is not the same entity as any of those partial matches. This can be verified by reviewing name and/or address variances between the screened entity and found matches. In cases where entities are located in countries using different alphabets, screening person must pay special attention to names taking different formats. Many times, it will be necessary to further review the other information listed, such as other names (e.g., AKA), addresses, date of birth and identity information of the partially matched entities.
- Exact matches are found: Similar to partial match, screening person and authorized individuals must review the matching fields and additional information on listed entities and confirm the match. Once confirmed, organization must stop processing the transaction and execute further analysis of the nature of the business transaction. Entities might be sanctioned for all types of or for certain type of transactions by the listing agency. Depending on the restriction type and legal jurisdiction, the listing agency must be consulted and if required an export authorization/license must be secured prior to initiation of the transaction.
In all above cases, record retention must be in place. Accordingly, it is highly recommended that results of all screening activities along with the clearance approvals by the authorized persons are documented.
It is important that the denied/restricted screening process must stop handling the transaction until the screened entity is cleared. Only the authorized persons should be allowed to approve the clearance if partial matches are found.
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Customer Case Studies
California based defense manufacturer ISTech has offices in the U.S., Asia, and Europe. ISTech lacked the comprehensive approach in complying with the U.S. EAR and ITAR. Thanks to ongoing support from Linqs, ISTech now can easily process the controlled technology globally. Access control processes are streamlined, and customer/vendor vetting process is fully automated with Linqs solutions. The company also maintains cloud based secure file sharing platform to enable collaborative product development.
Subsidiary of a Dutch Holding, North Carolina based industrial drive manufacturer FBX receives, processes, and handles EAR (600 series) and ITAR controlled technology in its facilities. Linqs assisted FBX to develop its compliance policy and procedures, and classified products while training employees. Company now has successfully segregated and isolated the design and production sites for specially designed defense articles, and maintains secure file sharing platform to enable collaborative product development with proper access controls.
With offices in the U.S. and France, Texas based TCraft’s product line includes jet engine components which are extensively used by the commercial aircraft manufacturers. Interested in undertaking defense article production, TCraft turned to Linqs for an assistance. Started with a development of a robust compliance program and employee training, our experts also classified hundreds of company products and technology. Linqs provides a continued support in document marking and access management to TCraft.