Blacklist screening

Export Privileges are denied by written order of the Department of Commerce. Each order affecting export privileges is published in the Federal Register. These orders are the official source of information about denied persons and are controlling if there is an inconsistency with anything on the lists identified below. The Federal Register from 1994 to the present is available online here. This link will take you to Title 15 – Commerce and Foreign Trade Subtitle B, Chapter VII, Sub-Chapter C – Export Administration Regulations (Parts 730 – 780).

FIRST, the denied person(s) may not, directly or indirectly, participate in any way in any transaction involving product, service, software or technology exported or to be, or in any other activity subject to the Export Administration Regulations (EAR), including, but not limited to:

A. Applying for, obtaining, or using any license, License Exception, or export control document;

B. Carrying on negotiations concerning, or ordering, buying, receiving, using, selling, delivering, storing, disposing of, forwarding, transporting, financing, or otherwise servicing in any way, any transaction involving any item exported or to be exported;

C. Benefiting in any way from any transaction involving exports.

SECOND, that no person may, directly or indirectly, do any of the following:

A. Export or reexport to or on behalf of the denied person;

B. Take any action that facilitates the acquisition or attempted acquisition by a denied person of the ownership, possession, or control of any product that has been or will be exported, including financing or other support activities related to a transaction whereby a denied person acquires or attempts to acquire such ownership, possession or control;

C. Take any action to acquire from or to facilitate the acquisition or attempted acquisition from the denied person of any product that has been exported from the United States;

D. Obtain from the denied person in the United States any product with knowledge or reason to know that the item will be, or is intended to be, exported from the United States; or

E. Engage in any transaction to service any product that has been or will be exported from the United States and which is owned, possessed or controlled by a denied person, or service any item, of whatever origin, that is owned, possessed or controlled by a denied person if such service involves the use of the product that has been or will be exported from the United States.

Servicing means installation, maintenance, training, repair, modification, software upgrades or testing.

THIRD, any person, firm, corporation, or business organization related to the denied person by affiliation, ownership, control, or position of responsibility in the conduct of trade or related services may also be made subject to the provisions of this order.

THE BLACKLISTS

These black listed individuals, entities and corporations can be found on the following web sites of various U.S. government agencies:

Denied Persons List
Bureau of Industry and Security, Department of Commerce

Entity List
Bureau of Industry and Security, Department of Commerce

Specially Designated Nationals and Blocked Persons List
Office of Foreign Assets Control (OFAC), Department of Treasury

Above also for Specially Designated Terrorist Organizations and Individuals, Specially Designated Narcotics Traffickers and Narcotics Kingpins and Foreign Persons Designated Under The Weapons of Mass Destruction Trade Control Regulations.

Debarred Parties
Office of Defense Trade Control (DTC), Department of State

Above also for Arms Export Control Act Debarred Parties, Designated Terrorist Organizations, International Traffic in Arms Regulations Munitions Export Control Orders, Nonproliferation Orders, Missile Proliferators, Chemical and Biological Weapons Concerns and Lethal Military Equipment Sanctions.

Country Policies and Embargoes
Office of Defense Trade Control (DTC), Department of State

Other U.S. and Worldwide LISTS available on the internet. (Please do a search on the internet to locate their sites)

U.S. Federal Register General Orders
European Union Council Regulation on Restrictive Measures to Combat Terrorism
Interpol Recently Wanted
Japan Foreign End Users of Concern
United Nations Consolidated List
The Wassenaar Arrangement on Export Controls (Multilateral)
European Union Common Foreign and Security Policy (CFSP) Sanctions List (EU)
Public Safety Canada National Security Listed Entities (PSC)
Royal Canadian Mounted Police Wanted List (RCMP)
Canada Office of Superintendent of Financial Institutions (OSFI) Consolidated List
Terrorism Financing Sanctions List (Entities other than individual)
Canada Office of Superintendent of Financial Institutions (OSFI) Consolidated List
Terrorism Financing Sanctions List (by Individuals)
Bank of England – Consolidated List of Financial Sanction Targets (GB)
Japanese Ministry of Economy Trade and Industry (METI) Foreign User List (JP)
Australia Department of Foreign Affairs & Trade (DFAT) Consolidation List
Interpol Recently Wanted List (Non Trade Compliance)
World Bank Listing of Ineligible Firms