May 15, 2008

Denied Entities Databases for Exports

· Denied Persons List: The BIS publishes the names of individuals and entities that have been found to have violated the U.S. export laws and regulations, and that have been denied export privileges for a certain period of time. U.S. citizens and corporations are prohibited from exporting merchandise to these individuals and entities. An updated version of this list may be found on the BIS’ website at:

http://www.bis.doc.gov/DPL/default.shtm.

· Unverified List: This list includes names and addresses of foreign persons who in the past were parties to an export transaction, and the BIS could not conduct a pre-license check or post-shipment verification. The involvement of a person designated on the Unverified List in an export transaction will raise a “red flag” with the BIS; therefore, U.S. exporters have an affirmative duty to inquire, verify or substantiate the proposed export transaction with such individuals to ensure compliance with all export laws and regulations. An updated version of this list may be found on the BIS’ website at:

www.bis.doc.gov/enforcement/unverifiedlist/unverified_parties.html.

· Entity List: The BIS also publishes a list of foreign end users involved in proliferation activities—an export license is required for export to these entities. An updated version of this list may be found the BIS’ website at:

http://www.bis.doc.gov/Entities/Default.htm.

· Specially Designated Nationals List: The Office of Foreign Assets Control (OFAC) administers a series of laws that impose economic sanctions against hostile countries, individuals and entities that pose a threat to U.S. foreign policy and national security. OFAC restricts financial trade transactions with certain individuals and entities that have been designated as Specially Designated Nationals (who are involved in terrorism, narcotics-trafficking, etc.). U.S. citizens and companies are prohibited from engaging in any financial dealings with these individuals and entities. An updated version of this list may be found on OFAC’s website at: www.treas.gov/offices/eotffc/ofac/sdn/index.htm

· The Debarred Parties List: The DDTC publishes a list entities and individuals that have violated the U.S. export laws and regulations and which are prohibited from exporting from the United States or receiving merchandise that was exported from the United States. (Even though this list pertains to violators of the International Traffic in Arms Regulations pertaining to defense articles and services, we believe that it is a good idea to screen against this list as well.) An updated version of this list may be found on the DDTC’s website at: http://pmdtc.org/debar059.htm.