by Taxseer 2290 Form 2290 e file
all intents, when it comes to export, trade and financial compliance—with which
businesses in both the U.S. and abroad have the obligation to comply—those
commonly-used terms can be considered relatively interchangeable.
common in the export compliance industry include: debarred party screening,
OFAC screening, watch list screening, sanctions screening, embargoed country
screening, Sanctioned Party List Screening (SPL), and Specially Designated
Nationals (SDN) and Blocked Persons screening.
while similar in nature, there are some differences, primarily in that some
terms are associated with specific regulations:
having a denied party designation
typically means that entity has been denied export privileges. In some
circumstances, it’s possible to do business with them, but if they happen to
export (or reexport) what they’ve purchased, that’s potentially an export
violation in the making. End User Statements, which certify on the buyer’s end
that they won’t export or re-export goods or materials, can be an effective way
to manage risk when dealing with denied parties.
these are individuals or entities upon which restrictions—either whole or
partial—have been placed. For example, they are prohibited from receiving some
items subject to the Export Administration Regulations (EAR), or a license is
required in order to conduct business with them. In other cases, it may be prohibited
to transact with them altogether. A restricted party is sometimes referred to
as a blocked party or entity.
parties: these are individuals or organizations that have been blocked on
account of a violation of the Arms Export Control Act administered by the
Directorate of Defense Trade Controls.
parties: these parties have been blocked as a result of the enforcement of U.S.
economic sanctions. Individuals and entities, as well as sanctioned and
embargoed countries, fall under the purview of the Office of Foreign Assets
Controls (OFAC). Some of OFAC’s watch lists include Specially Designated
Nationals (SDN) and Blocked Persons, Sectoral Sanctions, and Foreign Sanctions
Evaders, among others.
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