Denied / Restricted Party Screening is the fundamental building block of any export compliance program.
But how do you go about efficiently vetting potential matches to your screening information?
You want to be sure and thorough, and you want to keep a solid record of your vetting process, but you also want to keep it simple and down to as few steps as possible.
A workflow solution places each step of your restricted party screening process in a single dashboard, so there’s no need to blend details through outside application exchanges or intermediary translation steps. You can move efficiently through your restricted party screening to your incident managing practice to your decision administration in one fluid workflow, keeping the whole process fast and intuitive.
If your company subscribes to Visual Compliance, find out about the Compliance Manager Workflow tool for managing export incidents. It keeps the whole process, from screening to decision, incredibly fast and efficient, and it streamlines the often critical vetting workload. Visual Compliance also makes it simple to keep an ongoing record of all your export compliance activities in a central place.
Here are the three main steps for managing positive matches to your restricted party screening:
1. Recognize positive Denied Party Screening matches and review each one.
Review potential matches for each screening instance to assess details about each one, such as which list a match occurs on. Reference the search criteria entered at the time the search was performed to help determine where each match corresponds with your screening information. Scan the notes attached to the match. These notes are published with each list to better identify and describe the restricted party.
You may also want to check the Federal Register for more information about the particular company or individual in question. Visual Compliance offers a direct link to the Federal Register to make it easier for you to assess the information.
2. Choose to either clear positive matches or escalate them for further action.
When your vetting activity clears any matches from your concern, choose to clear the incident from your dashboard, so you can move on to the next. If there’s indication that a match may in fact be positive, choose to action that incident for further escalation.
In this way, you can swiftly move through a cue of potential matches with each decision you make triggering the appropriate next steps throughout your network.
3. Take a moment to add a comment for screening audit purposes.
Whether you choose to clear or action each export incident, pause after each choice to add a comment to each decision. By noting your thoughts down, you’re adding to the unfolding history of your company’s compliance activity and helping whoever must advance your decisions to understand why you chose to clear or action each one.
In the event some discrepancy occurs somewhere along the way, and a government investigation calls on your company’s export compliance logs, having a clear record of your positive match managing process goes a long way to proving your company’s active due diligence to uphold the law. Being able to prove active due diligence is a huge part of the bigger compliance picture.
