AEB Compliance
Solutions
Restricted party lists
18.11.2014
1
Against which restricted party lists should an EU company check?
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1.1
Relevant EU regulations
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1.2
Official lists that cover the EU regulations
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1.3
US lists to be checked
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2
Which lists are currently available in the AEB Compliance Solution?
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2.1
Lists offered by AEB
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2.2
Lists of Bundesanzeiger Verlag (Additional license fee)
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2.3
Lists of World Compliance (Additional license fee)
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2.4
Can AEB provide the German Frühwarnhinweise via data service?
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AEB Compliance Solutions: Restricted party lists
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1
1.1
Against which restricted party lists should an EU
company check?
Relevant EU regulations
For companies having their headquarters in the EU, strictly speaking only those sanctions
lists/denied-party lists are to be considered which are mentioned in the EU regulations or in national law.
There are two types of embargoes that make it necessary to screen companies’ and persons’ addresses. On the one hand, these are embargoes on individuals as defined in the EU Regulations
Nos. 881/2002 (Al-Qaida), 753/2011 (Afghanistan) and 2580/2001 (Terrorism) including all
amendments to these regulations.
On the other hand, there are EU embargoes on countries which include address lists, e.g. for countries such as Burma/Myanmar, Iran, Iraq, Congo (Democratic Republic), North Korea, Sudan, …
(EU regulations see at http://www.ausfuhrkontrolle.info/ausfuhrkontrolle/de/embargos/index.html
under BAFA >> Embargos (English Version of the EU regulations can be found under http://eurlex.europa.eu/en/index.htm) or the
Bulletin on country-independent embargo measures for combating Terrorism:
http://www.ausfuhrkontrolle.info/bafa/en/export_control/publications/export_control_information_lea
flet_terrorism.pdf.)
1.2
Official lists that cover the EU regulations
The addresses listed in these regulations are completely covered by the following lists:
UK financial sanctions: consolidated list of targets (formerly Bank of England List)
(https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets).
According to the authority HM Treasury, the list contains all addresses of EU regulations, UN sanctions and British legislation regarding the freeze of money and other financial means.
EU Common Foreign & Security Policy: consolidated list of persons, groups and entities
subject to EU financial sanctions (CFSP List)
(http://eeas.europa.eu/cfsp/sanctions/consol-list_en.htm)
Screening of the CFSP List is recommended by the German Licensing Authority BAFA in its Bulletin on country-independent embargo measures for combating Terrorism:
http://www.ausfuhrkontrolle.info/bafa/en/export_control/publications/export_control_information_lea
flet_terrorism.pdf
“…We believe that the easiest way to check the name lists is to use, free of charge, the EU’s database, which lists all persons, organisations and entities against whom financial sanctions have
been imposed. This database is regularly updated to take account of amendments to the legislation, and offers the following advantage compared with the consolidated legal texts: it brings together in a single database all persons listed in the name lists related to the combating of terrorism
as well as persons against whom financial sanctions have been imposed in the course of other
country-related embargo measures….”
AEB Compliance Solutions: Restricted party lists
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1.3
However, it is also recommended to companies located in the EU to perform screenings
against U.S. sanctions lists, because the United States require that their export control legislation is also applied outside the U.S. (e.g. for US re-exports). This applies in particular to parts
of the SDN list (s. below).
US lists to be checked
In the US there are a lot of name lists with very different meanings depending on the authority that
maintains the list.
Therefore the following website is a good strategy for a pragmatical definition of the for you relevant lists: http://export.gov/ecr/eg_main_023148.asp, as it contains the most important lists of several US authorities. These authorities have created a common consolidated list “US Consolidated
Screening List” in which the following individual lists are combined:
Denied Persons List
The Denied Persons List is compiled by the BIS (Bureau of Industry and Security) and lists individuals and organizations who have been denied export privileges in whole or in part. All business
transactions with a party shown on this list violating the mentioned type of denial are prohibited.
http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/denied-persons-list
Unverified List
A list of individuals and organizations compiled by the BIS where the BIS was not able to check the
end user during previous transactions. The status of entities having a ‘Red Flag’ on this list should
be clarified before the transaction is continued.
http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/unverified-list
Entity List
A list compiled by the BIS listing persons and organizations whose involvement in specific transactions is subject to specific license requirements according to the EAR (Export Administration Regulations). The list specifies license requirements that are applied to the listed entity. These license
requirements are supplemental to requirements and policies found elsewhere in the EAR.
http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list
Specially Designated Nationals List (SDN List)
A list compiled by the OFAC (Office of Foreign Assets Control, U.S. Department of Treasury). The
listed persons and organizations are subject to different kinds of sanctions. It is prohibited to US
persons worldwide to trade with the listed entities.
http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx
Entries on the SDN list are generally only to be observed by U.S. persons as the presidential decrees on which they are based do only relate to U.S. persons. However, due to specific requirements in the EAR, SDN name entries may also be relevant for foreign companies and persons if
they are specifically marked by the following supplements: [NPWMD] (for Nuclear Proliferation
Weapons of Mass Destruction), [SDGT] (for Specially Designated Global Terrorists), [SDT] (for
Specially Designated Terrorist), [FTO] (for Foreign Terrorist Organization), [IRAQ2] and/or [BUR-
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AEB Compliance Solutions: Restricted party lists
MA] §§ 744.8, 744.12, 744.13, 744.14, 744.18, 744.22 EAR. These entries are also applicable to
foreign re-exporters of goods which are subject to EAR.
The export/re-export of EAR goods to a listed person with the supplements NPWMD, SDGT, SDT,
FTO, IRAQ2 and/or BURMA is prohibited to non-US persons and is subject to a license requirement by the Bureau of Industry and Security (BIS). Every shipment which is not licensed is a violation of US regulations and subject to punishment.
Debarred List
A list of persons compiled by the DDTC (Directorate of Defense Trade Controls, U.S. State Department) which are directly or indirectly debarred from the export of defense articles (including
technical data or defense services) for which a license or permission is required according to the
ITAR (International Traffic in Arms Regulations).
http://www.pmddtc.state.gov/compliance/debar.html
Nonproliferation Sanctions
Various lists compiled by the U.S. State Department listing persons who have been sanctioned
based on different legal foundations. The publication in the Federal Register determines in detail
the sanctions to be applied to these parties. Some of these sanctioned parties are subject to the
BIS’ “denial policy” according to § 744.19 EAR, i.e. applications for granting licenses are refused.
http://www.state.gov/t/isn/c15231.htm
AEB Compliance Solutions: Restricted party lists
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2
Which lists are currently available in the AEB
Compliance Solution?
We extend our choice of restricted party lists step by step. The most demanded lists that are freely
available in the internet are offered by AEB in our data service. In addition to this service, we also
integrate the content of some partner companies providing restricted party lists for various countries.
You can verify which lists you are currently using in the AEB solution by opening the application
‘restricted party lists’ in the cabinet ‘Compliance Screening’.
2.1
Lists offered by AEB
Available EU lists

UK financial sanctions: consolidated list of targets (formerly Bank of England List)
Meaning of the list: see above.

EU Common Foreign & Security Policy: consolidated list of persons, groups and entities subject to EU financial sanctions (CFSP List)
Meaning of the list: see above.

UK HM Treasury Ukraine List: list of persons subject to restrictive measures in view of Russia's actions destabilicing the situation in Ukraine
Meaning of the list: see https://www.gov.uk/government/publications/financial-sanctionsconsolidated-list-of-targets/ukraine-list-of-persons-subject-to-restrictive-measures-in-view-ofrussias-actions-destabilising-the-situation-in-ukraine

UK Iran List - WMD End-Use Control: Licence Application for Iran
https://www.gov.uk/iran-list-wmd-end-use-control
Meaning of the list: see http://www.bis.gov.uk/assets/biscore/eco/docs/iran-list.
Available US lists

Denied Persons List
Meaning of the list: see above.

Unverified List
Meaning of the list: see above.

Entity List
Meaning of the list: see above.

SDN – Specially Designated Nationals List
Meaning of the list: see above.

List of Statutorily Debarred Parties
Meaning of the list: see above.

US Consolidated Screening List
Meaning of the list: see above.

US OFAC: Non-SDN
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AEB Compliance Solutions: Restricted party lists
Consolidated Sanctions List
Consists of following lists:
 Foreign Sanctions Evaders List (FSE)
 Sectoral Sanctions Identifications List (SSI)
 Palestinian Legislative Council List (NS-PLC)
 List of Foreign Financial Institutions Subject to Part 561 (the Part 561 list)
 Non-SDN Iranian Sanctions Act (NS-ISA)
Meaning of the list: see http://www.treasury.gov/resource-center/sanctions/SDNList/Pages/consolidated.aspx

US FINCEN: Money Laundering Concerns List (Section 311)
Meaning of the list see http://www.fincen.gov/statutes_regs/patriot/section311.html
Further available international lists

Japan: Ministry of Economy, Trade and Industry METI - End User List
End-User for Catch-All Control in Japan. Meaning of the list see
http://www.meti.go.jp/policy/anpo/englishpage.html

Switzerland: State Secretariat for Economic Affairs SECO – Overall list of sanctioned
individuals, entities and organizations
Meaning of the list see http://www.seco.admin.ch/themen/00513/00620/index.html?lang=en

Singapore: Monetary Authority of Singapore MAS – Investor Alert List (only available
for ASSIST4 Compliance 4.0)
Meaning of the list see http://www.moneysense.gov.sg/Understanding-FinancialProducts/Investments/Investor-Alert-List.aspx

World Bank Listing of Ineligible Firms
Meaning of the list see
http://web.worldbank.org/external/default/main?contentMDK=64069844&menuPK=116730&pa
gePK=64148989&piPK=64148984&querycontentMDK=64069700&theSitePK=84266
For prices and quotations, please get in touch with AEB. Contact via the AEB website: www.aebinternational.com
2.2
Lists of Bundesanzeiger Verlag (Additional license fee)
The total (always current) overview can be found under (hint: scroll to the end)
http://www.awr-portal.de/SubBoy/readme.txt
AEB customers need to license the sanctions lists directly with the provider. For the data service,
an order needs to be placed with AEB.
For a quotation, please get in touch with Bundesanzeiger Verlag directly. Contact details: Mr. Melzig (0049(0)6431/2891-11, [email protected])
AEB Compliance Solutions: Restricted party lists
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2.3
Lists of World Compliance (Additional license fee)
World Compliance offers more than 600 Listen world wide. Therefore it is necessary to spezify
which lists from which countries you really need.
World Compliance lists need to be licensed directly with the provider. If you are interested, please
get in touch with AEB. We will help you to get the matching contact at World Compliance. For the
data service, an order needs to be placed with AEB.
2.4
Can AEB provide the German Frühwarnhinweise via data
service?
The so-called early warning notifications by the German Federal Ministry of Economics are not
public and will only be made available to the companies by the respective Chamber of Commerce
in charge. Therefore AEB is not allowed by law to distribute this list via data service.
If your company receives the early warning notifications from the Chamber of Commerce and if you
would like to check them by using the AEB Compliance solution, you can import the addresses of
the Early Warning List in your Compliance solution as a manual sanctions list. AEB offers this data
import also as a one time service, which requires you to provide the list.
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AEB Compliance Solutions: Restricted party lists
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