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#2172356 - 04/06/18 06:14 PM Bureau of Industry and Security
jhoch Offline
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Joined: Nov 2014
Posts: 66
The Bureau of Industry and Security (BIS) website indicates that the BIS lists (Denied Person List, Entity List, Unverified List and the Consolidated Screening List) are for export transactions. My company already screens potential customers and our existing customer portfolio against all the OFAC lists as well as EU and UK lists. It's my understanding that unless we're entering into an export transaction (which is extremely rare) there is no need to screen against the BIS lists. Our global parent (which isn't always right) is saying we have to screen the BIS list regardless of an export transaction. Any thoughts? Am I missing something?

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#2172456 - 04/08/18 01:58 PM Re: Bureau of Industry and Security jhoch
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,598
Galveston, TX
"Have to screen"? You don't even "have to" screen for OFAC. Like all such screening, it is a risk based decision. What are the identified risks for a financial institution if someone is on this list? What risks are you mitigating by doing the screening? What is the proper course of action if you receive a match?. Only the answers to those question will provide the answer to your question.
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#2172971 - 04/11/18 03:21 PM Re: Bureau of Industry and Security jhoch
jhoch Offline
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Joined: Nov 2014
Posts: 66
I know none of the lists are "have to" from a regulatory perspective. When I say "have to" it's because our global policy owned by global compliance dictates what lists we are "required" to screen against. So they've already made a risk based decision of what lists should be screened against. The policy indicates 10 or so sanctions lists that all entities are required to screen against. I'm arguing with our global compliance team that the BIS list doesn't belong on that "required" list because it only applies to export transactions and we're not doing export transactions. Right now because of that policy I have to screen my entire customer portfolio against the BIS list. Just trying to see if I'm missing something in regards to the BIS list applying more than just export transactions.

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#2172989 - 04/11/18 04:04 PM Re: Bureau of Industry and Security jhoch
rlcarey Online
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rlcarey
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Posts: 77,598
Galveston, TX
So they've already made a risk based decision of what lists should be screened against.

Have they shared the risk assessment? Only that is going to give you any ammunition.
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