Screening Business Partners Against Denied Lists - 2
Screening activity typically involves searching for name and/or address match between the trade partners and restricted parties. Since the watch lists are subject to frequent changes that are often effective immediately, screening is essentially a repetitive task. The best practices in the industry today recommend three basic approaches in regards to the timing and nature of the screening:
1- Party-based screening: Screening of all business partners every time the restricted party lists are updated.
2- Transaction-based screening: Screening of only the relevant business partner(s) prior to the occurrence of the each business opportunity and/or transaction.
3- Hybrid screening: Screening of all business partners periodically in addition to screening of only relevant business partner(s) prior to each transaction.
Considering the fact that most up-to-date restricted party lists should be used for either approach, screening can be manually intensive work. In case of an existence of large amount of trade partners using a software solution is inevitable. Companies should look for the automated screening software which promptly updates all applicable watch lists when they are updated by the source authorities.
Automated software generally seeks an exact match between the trade partners and the restricted entities. However, due to differences between the Latin and native alphabets many of the foreign restricted entities have name and address variances. As such, the software should not only look for the exact match, it should also have the search function employing "fuzzy logic" algorithm, also known as finding the similar sounded names or phonetic matches.
In order to decrease the redundancy and workload among different business teams, it is suggested that screening activity to be centralized. In many cases, Shipping and Trade Compliance (if exists) personnel perform the most of the screening. Other functions, such as Human Resources, Customer Service, Sales, Security and Engineering teams as well as remotely located offices can also own the parts of the process when the need arises. Organizations may consider keeping certain entities exempt from a periodical screening process. Those that are exempt would include the entities that are owned or controlled by the organization itself (i.e., subsidiaries, Joint-Ventures, etc.) and the U.S. Government agencies.
Best Practices in Timing and Responsible Functions:
Suppliers, Service Providers, Vendors and Subcontractors:
Time for Screening:
- Prior to considering new suppliers, vendors, service providers, and subcontractors,
- Prior to submission of new request for quote and/or Purchase Orders
Responsible Function: Purchasing, Procurement and/or Trade Compliance.
Customers, Recipients of Software and Technology, Financial Institutions and Brokers:
Time for Screening:
- Prior to considering new customers and recipients
- Upon receipt of quote requests and Purchase Orders (for existing customers)
- Prior to shipping/export
- Prior to disclosing software and technology
Responsible Function: Customer Service, Sales/Marketing and/or Trade Compliance.
1- Party-based screening: Screening of all business partners every time the restricted party lists are updated.
2- Transaction-based screening: Screening of only the relevant business partner(s) prior to the occurrence of the each business opportunity and/or transaction.
3- Hybrid screening: Screening of all business partners periodically in addition to screening of only relevant business partner(s) prior to each transaction.
Considering the fact that most up-to-date restricted party lists should be used for either approach, screening can be manually intensive work. In case of an existence of large amount of trade partners using a software solution is inevitable. Companies should look for the automated screening software which promptly updates all applicable watch lists when they are updated by the source authorities.
Automated software generally seeks an exact match between the trade partners and the restricted entities. However, due to differences between the Latin and native alphabets many of the foreign restricted entities have name and address variances. As such, the software should not only look for the exact match, it should also have the search function employing "fuzzy logic" algorithm, also known as finding the similar sounded names or phonetic matches.
In order to decrease the redundancy and workload among different business teams, it is suggested that screening activity to be centralized. In many cases, Shipping and Trade Compliance (if exists) personnel perform the most of the screening. Other functions, such as Human Resources, Customer Service, Sales, Security and Engineering teams as well as remotely located offices can also own the parts of the process when the need arises. Organizations may consider keeping certain entities exempt from a periodical screening process. Those that are exempt would include the entities that are owned or controlled by the organization itself (i.e., subsidiaries, Joint-Ventures, etc.) and the U.S. Government agencies.
Best Practices in Timing and Responsible Functions:
Suppliers, Service Providers, Vendors and Subcontractors:
Time for Screening:
- Prior to considering new suppliers, vendors, service providers, and subcontractors,
- Prior to submission of new request for quote and/or Purchase Orders
Responsible Function: Purchasing, Procurement and/or Trade Compliance.
Customers, Recipients of Software and Technology, Financial Institutions and Brokers:
Time for Screening:
- Prior to considering new customers and recipients
- Upon receipt of quote requests and Purchase Orders (for existing customers)
- Prior to shipping/export
- Prior to disclosing software and technology
Responsible Function: Customer Service, Sales/Marketing and/or Trade Compliance.
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