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In the current international political landscape, the export compliance professional’s work is never done, especially when it comes to screening. Huawei and its affiliates being added to the entity list is just the latest example of how the U.S. government uses targeted sanctions. New entities are added to screening lists on a regular basis, and companies are required to screen for matches and monitor for any changes.
The reality is there are many ways to perform screening. The important thing is finding what works for your company. A world class integrated system that costs six digits a year may be overkill for a company exporting once a month. Conversely, a major international trader shipping thousands of containers a month probably shouldn’t be screening manually. Your company’s screening program shouldn’t be too big or too small- it needs to be just right, keeping you and the government happy.
As the Sanctions and Denied Parties pile up, OFAC has released new guidance on what a “Sanctions Compliance Program” (SCP) should look like and penalty levels just rose again (last week) pushing IEEPA penalties over the $300K mark. With new guidance in place and very long reaching enforcement precedents in the last year, OFAC is set with more leverage than ever to enforce hefty penalties on companies even unknowingly linked to a denied party. That risk creeps exponentially if that company does not have a strong SCP with routine screening practices. This webinar will provide a high level review of what OFAC says an SCP should include, the precedent of past cases, the rising penalty costs, and a thorough review of practical steps to performing Sanctions and Denied Party Screening.
This webinar will have three major topics: First, what lists are really required to be screened and why they are required. Second, how to properly monitor the screening lists and what to do if you find a match. Third, looking at past examples of enforcement and recent updates to the lists.
This webinar will cover:
· Regulatory Requirements for Screening
o Department of State
o Department of Commerce
o Treasury Department
o Other Denied/Restricted Party Lists
· Suggested Due Diligence for Exporters and How to Do it
o Screening Before a Transaction
§ “Know Your Customer”
§ Building a Program that is Just Right
§ How Much is Too Much?
o Looking for Red Flags
o Screening Transactions
§ Tips and Tricks
§ Fuzzy Logic and How to Use It
§ Clearing False Positives
o Monitoring a Shipments Destination
o End-Use Verification
o Screening After a Transaction
§ “Regressive” Screening
§ Monitoring for Changes
· Denied Party Enforcement Cases and Updates
o OFAC Enforcements
o Recent Changes to Screening Lists
Who should attend the webinar?
This webinar will be beneficial for export compliance professionals, supply chain professionals, freight forwarders, authorized agents, and carriers because all the above are responsible for screening. Screening may seem like an overwhelming task, but once understood and scaled to match a company’s risk, a screening program can be a fluid integral part of the natural business process.
Presently, Martin is an instructor with City University of New York's Baruch College Continuing and Professional Studies (CAPS), where he teaches import, export, and other international trade courses. In 2013, Martin received the Outstanding Instructor of the Year Award from Baruch CAPS. Martin has also taught international trade courses at Fashion Institute of Technology and Pace University in New York City. Martin is also of counsel to GRVR Attorneys (www.exportimportlaw.com), which specializes in customs and international trade matters.
Martin is a former U.S. Customs officer (senior inspector and import specialist), who was stationed at land (Champlain-Rouses Point, NY), air (JFK International Airport and Newark Liberty) and sea (Newark) ports of entry. While with U.S. Customs at the Port of New York/Newark, he was also a member of the agency's export control branch.
Martin is also a former special agent with the U.S. Department of Defense, assistant prosecutor with the Office of Hudson County (NJ) Prosecutor, and an executive with a global FMC-licensed Ocean Transportation Intermediary. Martin was also a trade consultant with Unz & Co.