Overview
Confusion abounds over the recent proliferation of sanctions and export control lists. In addition to the US Treasury Department's Office of Foreign Assets Control ("OFAC"), companies now have to contend with lists from, among others, the Commerce Department’s Bureau of Industry and Security ("BIS"), the State Department, and numerous state-level divestment authorities, to name a few.
List management and name screening are greatly simplified through the use of automated matching software, web-based due diligence portals, and other tools. But when it comes to decision making, nothing (yet) can beat a well-informed compliance manager.
We provide a table with the major features of key US sanctions and export controls lists.
Some lists apply to US persons (i.e., US nationals and permanent residents, all persons in the United States, companies incorporated under US law and their foreign branches), while others apply to both US and non-US persons. The latter includes the Entity List which generally applies to all US origin goods, technology, and software, as well as some foreign-produced items.