SANCTIONED PARTY LIST

SCREENING IN SAP GTS

Governance, Risk and Compliance (GRC) automate
controls to facilitate compliance with financial,
environmental, health and safety and trade regulations,
enforce internal controls, increase the efficiency of audits,
identify risks and employ proper governance procedures
to keep all these activities up to date and effective
A sanctioned party list contains a list of persons and
companies with whom trade is prohibited by law. These
boycott lists are issued by government agencies and can
be obtained from data providers. All traders must comply
with these lists.
The Sanctioned Party List (SPL) Screening service in SAP
GRC Global Trade Services (SAP GRC GTS) lets you check
business partnersaddresses (such as the consignee)
automatically against the sanctioned party lists before
goods are exported. It is a system-independent solution
that performs and logs the SPL check and is fully
integrated into the complete business process.
Master Data
Master data including sanctioned party lists, business
partners and comparison. You can also monitor lists that
are due to expire soon and that can be archived
SPL Screening for Logistics
Sanctioned party list
A list of individuals and companies that have been
formally denied export privileges or sanctioned by the US
Government. It includes the US Commerce Department

Denied Persons List, US Treasury Department Specially

Designated Nationals List, US State Department Statutory
Debarred Parties, and other parties subject to US
Government tradesanctions.Under US ITAR regulations,
person or firm ineligible to participate in transactions
involving ITAR-controlled products and technology
(military ruggedized products, TEMPEST, and wargaming
software). Names of Debarred Parties are published by
the US State Department and are included in the
Companys Denied Parties List (DPL). Debarred Parties
may receive US Department of Commerce-controlled
products and services.
With respect to US export regulations, a person or firm
that has been formally denied export privileges by the US
Commerce Department. The names and addresses of
Denied Parties are published by the Commerce
Department in the Denied Persons List and are listed in
the Companys Restricted Parties List (RPL).
Denied Persons List
A list, referenced in Supplement No. 2 to Part 764 of the
US EAR, of specific persons that have been denied export
privileges, in whole or in part. The full text of each order
denying export privileges is published in the US Federal
Register. Formerly known as the Table of Denial Orders
(TDO).
SPL screening
SPL Screening while initiating the business with
customer
SPL Screening when business partner change the
address

SPL Screening when document partner change the

address
-

Periodic check on business partners

Periodic check when document partner changes

address
-

Simulated SPL screening of Business partners

Simulated SPL screening of document partners

Releasing blocked Business partners

Releasing blocked Documents

Monitoring Sanctioned party lists

Monitoring positive / negative lists

Monitoring Blocked business partners

Monitoring Blocked documents

Audit trail

Embargo
As defined by the United States, a country with which the
US will not trade. It is US policy to deny license
applications for exports and re-exports to these countries,
with few exceptions. US License Exceptions cannot be
used for deliveries to these countries, with few
exceptions. The Embargoed Countries are:
Cuba

Myanm
Iran ar

Sudan

Antiboycott Laws/Regulations
The laws/regulations of the US and other countries which
forbid compliance with unsanctioned economic boycotts,
and which may require reporting to national governments
requests for boycott-related certifications or statements.
What is Antiboycott Screening?
An economic boycott is a program under which a
country (or group of countries) refuses to do business
with another country, its companies, or citizens in an
attempt to cause economic damage. Under U.S. law, an
unsanctioned economic boycott is a boycott against a
country friendly to the United States.
Boycott-related requests are requests to comply with a
boycott, or to furnish information which will be used in
support of a boycott. Boycott-related requests may be
formal or informal, oral or written.
The US and other national governments prohibit direct or
indirect participation in certain economic boycotts, for
example, the League of Arab States Boycott of Israel. US
law and regulations require that most requests received
by US firms to enter into agreements, furnish information
or take actions supportive of such boycotts be reported to
the Government.
The primary boycott of Israel bars the importation of
Israeli goods or services into the boycotting Arab State.
There is also a secondary aspect of the Arab Boycott,
which precludes dealings with firms or persons in third
countries that have been blacklisted by the Central
Boycott Office because of their relationship with Israel.

The countries which currently enforce the boycott of

Israel and blacklisted parties are: Kuwait, Lebanon, Libya,
Qatar, Saudi Arabia, Syria, the United Arab Emirates, and
Yemen. Iraq is not included in this list, but its status with
respect to future lists remains under review by the
Department of Treasury.
The following boycott-related terms, phrases and
conditions are illustrative only and not exhaustive.
A certificate of origin must be provided stating the
products contain no {boycotted country} origin product.
A certificate must be provided stating that selling
company does not have facilities in a {boycotted
country}.
A certificate must be provided stating that company has
no reason to be blacklisted by the Arab Boycott Office.
Negotiations by banks whose names are included in the
Israeli Boycott blacklist are not acceptable.
A certificate must be provided that company has no
facilities in a {boycotted country} nor does it employ
persons of any particular origin or faith.
A certificate must be provided stating that company does
not have any foreign partners or foreign ownership.
Instruction that no six-point star {or other religious or
ethnic symbol} may be used on the goods, packing, or
case.
Instruction that company agrees to abide by the laws of
{boycotting country}, including the laws relating to the
boycott of a {boycotted country}.
A certificate must be provided that the aircraft is
otherwise eligible to enter the airports of {boycotted
country}.

A bill of lading must be provided that states that the

carrying vessel is allowed to enter {boycotting country}.
Contract clauses such as: The Tenderer agrees to comply
with all the laws of {boycotting country} or The Vendor
shall abide by and comply in all respect with the rules of
{boycotting country}.
End user screening
Mandatory Trade due Diligence Screening of End-Users
Note: An End-User is defined as the company or person
that ultimately receives and uses the products and/or
services. An End-User cannot be a broker, freight
forwarding agent, intermediary or a warehouse location.
US and other national government laws/regulations and
Global Trade policies require end-user and ultimate
consignee information made known to exporting
company to be screened in accordance with exporting
companys Restricted Parties List (RPL), Non-Proliferation
(NPS), Trade Sanctions & Embargoes, and Diversion Risk
screening policies.
The purpose of mandatory screening is to ensure that
exporting company complies with US and other national
government export regulations to neither directly nor
indirectly conduct business with sanctioned/ embargoed
parties, countries, or end-users engaged in prohibited
activities without having obtained prior government
authorization.
BOYCOTT OF ISRAEL The United States and other
national governments consider the boycott of Israel to be
an unsanctioned economic boycott. The following
countries are known to or may participate in the boycott

of Israel. Special care must be taken when processing

transactions for these countries to ensure company does
not comply with boycott related requests.
Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United
Arab Emirates, Yemen.
Note: This list is for information purposes only. Boycottrelated requests may originate from countries other than
those listed above. Absence from this list does NOT mean
company is relieved from responsibility for screening for
boycott related requests.
WHAT IS DIVERSION RISK SCREENING?
Diversion is the transfer of products or services to
individuals, companies, countries, or uses without
appropriate government export authorization.
The exporting company must exercise due diligence in
dealing with customers to ensure that exports and
reexports of commodities and technologies are not used
for or diverted to end-uses prohibited by applicable
export regulations. Diversion Risk Screening helps
ensure products and services will not be diverted to
unauthorized parties or uses.
Examples of diversions include the delivery of products
or services to a Restricted Party or sanctioned or
embargoed country, or for proscribed uses such as the
development of weapons of mass destruction. A
diversion can take place without physical movement of
a product if persons use the product for unauthorized
activities. Diverters try to act as normal customers but
often give themselves away by leaving signs or
indications to their illegal intentions. These signs or

indications are called diversion risk indicators or red

flag indicators.
Diversion Risk Screening should be used at all phases of
the order processing system.
DIVERSION RISK SCREENING REQUIREMENTS
Compliance manager must be alert for any unusual
transactions, delivery instructions, or requests that are
out of the ordinary and may signal a potential diversion.
The Diversion Risk Indicators Checklist contains examples
of out of the ordinary requests that may signal a
potential diversion. This Checklist may be used for
diversion risk awareness purposes, or to document
Diversion Risk Screening for specific transactions where
evidence of screening is required under national record
retention requirements.
Diversion Risk Screening must occur at all phases of order
processing and anytime the customer requests changes
to the existing order. For non-revenue shipments,
screening must be performedby the requestor of the
shipment.
Any transaction indicating a potential diversion risk must
be placed on export hold and escalated to Compliance
Manager for advice and resolution in accordance with the
Diversion Risk Escalation Procedure of the individual
company. All records must be retained for audit purposes.
Check list for Diversion Risk
Whether the customer is using Intermediate consignee,
whether its location is incompatible with ultimate end
user
Whether the customer wants only Ex works , delivery

terms
Check whether the customer is suspected to have
dealings with embargoed countries
Whether the customer ask for only cash payment not
interested in LoC payment
want the document through non- banking channel only
whether the products received by the imported can be
diverted to embargoed country. Say for example the
product export to Afghanistan can be easilTy reexported
to Iran
SPL screening for Human Resources
SPL screening is also possible for your own employees
due to integration of SAP HCM with SAP GTS. In fact, SPL
screening is possible for the complete movement of
humans within organization; this includes foreign travel
by the employee for the business purpose, vendor visit
to the organization for the purpose of business, and new
employee recruit. This requires Governance, Risk and
Compliance (GRC) policy framework for an organization to
conduct check and monitor the human capital movement
within or outside organization.
Embargoed National
A person who holds citizenship of an embargoed , has NO
other citizenship, NO green card, NO permanent
residency in another country, NO refugee or asylum
seeker status in another country.
Embargoed Party As defined by the US, a person or firm
acting on behalf of or as an agent of a country subject to
US embargo. The US Department of Treasury Office of
Foreign Assets Control (OFAC) publishes lists of these
parties (the list of Specially Designated Nationals &
Blocked persons). US firms are prohibited from doing
business with any party on the list or with any other party

owned by or acting on behalf of an embargoed country,

with few exceptions. The names of Embargoed Parties
published by OFAC should be included on the SAP GTS
Restricted Parties List (RPL)
SPL Screening for Financial Accounting
The incoming and outgoing payments are required to
monitor for the companies doing transactions globally.
These includes bank and insurance companies also need
to be screened along with payer and consignees address.
Financial institutions can insure that sanctioned persons,
groups and organizations are recognized in advance of
payment transactions taking place, and, as a result,
freeze funds or financial resources to prevent
transactions being performed. These sanctioned parties
are published and updated on a regular basis in different
countries and by different organizations, and may
contain, in some cases, the same sanctioned parties.
The compliance policy needs to screen the bank from
which company receives L/C if the organization involves
in letter of credit payment transaction with customer. For
example, a U.S. bank would have to reject a wire transfer
between two third-country companies (non-SDNs)
involving an export to a non-SDN company in Sudan.
Since there is no interest of the Government of Sudan or
an SDN, there is no blockable interest in the funds. The
U.S. bank cannot process the transaction because that
would constitute a transaction in support of a commercial
activity in Sudan, which is prohibited by the Sudanese
Sanctions Regulations. Similarly, a U.S. bank could not be
involved in the financing of a prohibited transaction. A
U.S. bank cannot so much as advise a letter of credit if
the underlying transaction is in violation of OFAC
regulations. Please note that the Iranian Transactions
Regulations contain no blocking provisions

(refer: http://www.treasury.gov/resourcecenter/faqs/Sanctions/Pages/answer.aspx). Insurance

companies and banks are required by laws such as the
Patriot Act (Providing Appropriate Tools Required to
Intercept and Obstruct Terrorism) in the U.S. to prevent
payment transactions taking place with people who
appear on the sanctioned party lists
The Sanctioned Party List Screening service in SAP
Compliance Management enables you to screen your
business partners, thereby ensuring that you comply with
national and international embargoes against countries
and sanctioning of individuals and companies. To do so,
you can perform compliance checks and legal controls at
every stage in your logistics process, from quotation
creation right through to billing document creation.
The integration of SAP GTS and Financial Accounting
covers the following functions:

Creation of sanctioned party lists

Transfer and replication of the relevant FI business

partners to SAP GTS

SPL screening of the relevant business partners

SPL checks against account holders

SPL checks against notes to payee

Synchronous checks of the business partners

against SPL data during the payment transactions

Manual post processing of the checked business

partners

The Sanctioned Party List Screening service can also be

integrated with SAP for Insurance and SAP for Banking,
among others.
To use SPL Screening for Financial Accounting, SAP Global
Trade Services (SAP GTS) and Financial Accounting
Current Accounts (FI-CA), can either run on the same
system or on different systems using Remote Function
Calls (RFCs).
Cross Area Monitoring
The tab pages for the business areas Logistics, Human
Resources, and Financials contain the following:
Asynchronous screening
Periodic Screening of business partners and document
partners (in dialog and in the background)
Sanctioned party list screening of business partners with
updated sanctioned party lists (in dialog and in the
background)
Simulated sanctioned party list screening
With this function you can simulate the SPL screening for
a business partner. This is very useful as a test SPL check
to see whether a new partner address would be blocked
by the system for business transactions in a live SPL
check.
Analysis of audit trail data (SPL screening logs)
You have to log and save all sanctioned party list (SPL)
screening activities to keep them accessible for official
audits within the statutory retention period. SAP GRC
Global Trade Services (SAP GRC GTS) logs the results at
the legal regulation level. The logs enable you to keep a
record of all the SPL screening your company has carried
out, giving you an important source of documentation for

legal purposes. You can archive these logs to reduce the

load on your system and delete them from the tables
once you have done this. The audit trail provides you with
proof you need to present periodically to customs
authorities, to demonstrate exactly which checks were
performed, on which parties and when, and to show the
results of these checks.
Monitoring of blocked business partners and documents