A sanctions check list can quickly become an extensive and sometimes difficult workload to manage.
In this article, we’ll introduce various software solutions that can help support you in checking of sanctions and embargoes.
However, it is important to know that software cannot guarantee 100% accuracy.
Commercial software or free Justice Portal?
When working through the sanctions checklist, companies have the choice between:
- the free justice portal of the federal and state governments and
- a paid software that can be purchased, rented or leased.
Sanctions list review on the Justice Portal
Companies can carry out a limited review on the website of the federal and state justice portals. The advantage is that there are no costs, registration or certificates necessary.
However, the scope of review via the judicial portal is very limited, and only checks Regulation (EC) No 881/2002 in connection with sanctions against the Taliban.
Yet there are many other important sanctions lists which are often unavoidable.
Additionally, the examination on the Justice Portal is quite lengthy and cumbersome, as only individual addresses can be entered. Checking the entire address stock by uploading it is unfortunately not possible.
Moreover, companies do not receive a protocol on the verification process of certain address data. Under certain circumstances, however, a protocol can serve as important evidence for customs during custom-house examinations and field audits.
The Justice Portal also cautions that a match between the person sought and the person found in the sanctions list are NOT equivalent. A match means, rather, that the names bear a similarity or are identical, according to the portal.
Companies must therefore conduct further research in the event of a match as well as an official investigation to be certain.
Commercial Software Solutions
Companies that are also active internationally should use certain software for the sanction list check in order to simplify the entire process and save costs.
Depending on the software, different sanction lists can be checked. The advantage of many software solutions is that they operate in the background with little disruption, similar to a virus scanner. Most software solutions primarily check individual address data as well as the address inventory. In addition, the software usually maintains an audit report, which companies can submit to customs as proof of audit.
It remains problematic, however, that software providers are not bound to a standardized search algorithm when designing their products. This means that the results and matches can differ depending on the provider and software when matching the same address data.
Companies must also calculate the costs of purchasing the Software as well as the costs per inspection process, depending on the price model.
Furthermore, when selecting a software, companies should ensure that it will allow them to flexibly adjust and update the scope of the sanctions list review.
Here you will find a selection of software solutions:
The SANSCREEN software offers a sanction list check in which current international checklists can be selected. Typos or alternate spellings are also taken into account during the review so that the search and match rate are optimized. Additionally, a record is made of the review. Integration into your CRM and ERP systems is also possible.
SANSCREEN also offers a module where the sanctions list check is integrated into the export declaration.
There are two ways to implement it:
The ASP option works with a web-based version. ASP can be advantageous for certain company structures, as it only requires monthly license fees without necessitating in-house IT support to maintain the software.
The alternative — an “in-house solution” — provides software that must be installed locally but is available throughout the company network. Individual adjustments can be made and the company itself manages its own data. It is therefore particularly well-suited to companies whose network is disconnected from the Internet.
The following sanctions lists can be checked:
- EU_CFSP (Common Foreign and Security Policy (European Commission))
- GB_HMT (Consolidated list of Financial Sanctions Targets in the UK)
- US_SDN (U.S. Treasury Department – Specially Designated National List)
- US_DPL (U.S. Bureau of Industry and Security – Denied Persons List)
- CH_SECO (SECO-Liste Switzerland)
Optionally, further sanction lists can be included in the examination for an additional fee.
The software easycompliance offers different rates that vary in cost and scope of the review. The current sanctions lists are made available in cooperation with the Bundesanzeiger Verlag.
Companies must therefore additionally subscribe to the Bundesanzeiger-Verlag for individual tariffs.
If necessary, a so-called PEP review (examination of politically exposed persons) can be arranged in addition to the sanction list examination.
PEP can be persons with public offices, such as heads of state and government, ministers, members of Parliament, senior judicial and government officials, ambassadors or heads of state enterprises. If a company is proven to have a relevant connection to such PEP, the accusation of money laundering, corruption or tax evasion is quickly raised.
The provider BEO offers three tariffs, which can also be used to check entire address lists. Depending on the examination effort, a basic version may be sufficient. With this option, however, the company pays per review.
In particular, medium-sized and large companies with a large number of addressees can carry out up to 100,000 tests in the Basic 100T, or an unlimited number of reviews with the in-house solution.
With this provider, it is also possible to choose between a web-based software or installing a local software.
DBH sanctions list screening with Advantage Compliance
Advantage Compliance software solution from DBH consists of a total of three modules:
- The Sanctions List Check
- Tariff classification to support the classification of goods in the customs tariff
- Export control for the implementation of embargo and dual-use testing
According to the DBH, the content of the review is updated daily to the information board of the Bundesanzeiger Verlag (TARIFE) and on EZT-Online, from German customs. The DBH also indicates that it is possible to integrate the modules into existing SAP systems
Through purchase of Advantage Compliance, companies can manually check individual address data records, or automatically with a web client. Moreover, complete data sets can also be reviewed through batch processsing (or “batch testing“) in the ERP/SAP system)
The provider ID Prove also offers a software solution for checking the EC antiterrorism regulation.
Companies have the choice between 3 price rates at ID Prove, which each offer vastly different ways to use the software. Businesses with a larger number of employees should anticipate higher costs and will need to calculate the expenditure for each office and location.
European sanctions lists are included in each price rate. US lists can be booked optionally, if needed. If integrating into the intranet as well as linking to an existing SAP System is required, then a higher investment will be necessary.
Addressware Compliance is a provider that also enables an overall review for an unlimited amount of address data. Addresseware Compliance offers a search identification of relevant persons, such as PEP. A test report is also included. To ensure up-to-date reference data for the sanctions lists, the software cooperates with the Bundesanzeiger Verlagsgesellschaft as well as other organizations.
Pixi Descartes Denied Party Screening
The Pixi Descartes Denied Party Screening software checks incoming customer and supplier orders according to current sanctions lists. According to Descartes pixi, the sanction list check software can also be purchased in combination with other solutions from the same company, such as pixi ERP Enterprise Resource Planning or pixi WMS Warehouse Management.
FORMAT’s sanctions monitor checks against current sanctions lists based on regulations (EC) No 881/2002 and 2580/2001. Further information on the scope of the examination and more can be obtained from the provider.
Ask about sanctions list verification and software solutions - we would be happy to help you.
Dieser Artikel wurde am 31. August 2020 erstellt. Die fachliche Zweitprüfung hat Rechtsanwalt Dr. Tristan Wegner durchgeführt.