Sanctions Module
Any company on the UFLPA entity list, the XPCC, or any other companies with known ties to forced labor will be flagged.Multiple third party databases are leveraged to offer this service including ownership records, shipping records, court records,media mentions and more.
Benefits of Running Sanctions Checks On Your Suppliers
Companies that engage with sanctioned suppliers may face legal liabilities, reputation risks, and financial losses. The following are some of the legal hazards that companies need to be aware of when dealing with sanctioned suppliers:
Violations of Trade Sanctions
Companies that engage with sanctioned suppliers may violate trade sanctions imposed by governments. These violations can lead to fines, penalties, and even criminal prosecution. For example, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) has the power to impose civil and criminal penalties on companies that violate US sanctions laws. Companies that engage with sanctioned suppliers may also face trade restrictions, including the suspension of import and export licenses.
Contractual Liabilities
Companies that engage with sanctioned suppliers may face contractual liabilities. Contracts may contain provisions that require compliance with sanctions laws, and failure to comply may lead to breach of contract claims by customers or suppliers. In addition, contracts may contain indemnification provisions that require companies to pay damages resulting from a breach of sanctions laws by their suppliers.
Reputational Risks
Companies that engage with sanctioned suppliers may face reputational risks. Customers, investors, and other stakeholders may view engagement with sanctioned suppliers as evidence of non-compliance with ethical and legal standards. Such negative perceptions can damage a company's reputation and brand, leading to decreased sales and market value.
Financial Losses
Companies that engage with sanctioned suppliers may face financial losses. Sanctions can lead to the freezing of assets, the imposition of trade restrictions, and the suspension of import and export licenses. Such measures can disrupt supply chains and lead to increased costs and lost revenues.
How It Works
Use Cases For Sanctions Module
The United States has banned products that are connected to supply chains in Xinjiang, China, due to concerns of human rights abuses against Uyghur Muslims in the region. In 2020, the US Customs and Border Protection (CBP) issued Withhold Release Orders (WROs) against certain products originating from Xinjiang, including cotton, tomato products, and hair products, to prevent the import of goods produced with forced labor.
The US has also imposed sanctions on Chinese entities and individuals involved in the human rights abuses in Xinjiang, including the Xinjiang Production and Construction Corps and the Xinjiang Public Security Bureau. Companies must ensure that their supply chains are free from forced labor and comply with the WROs and sanctions regulations to avoid legal and reputational risks.Companies must comply with various regulations when engaging with sanctioned suppliers in their supply chain.
In the United States, the Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions based on US foreign policy and national security goals. The OFAC has published guidance for companies on compliance with sanctions laws and recommends that companies conduct due diligence on their suppliers and monitor their activities.
The European Union also imposes sanctions on individuals and entities, and companies must comply with the EU's sanctions regulations. The UK's Office of Financial Sanctions Implementation (OFSI) administers and enforces financial sanctions, and companies must comply with UK sanctions laws. In addition, the United Nations imposes sanctions on countries and individuals, and companies must comply with UN sanctions regulations.
Overall, companies must be aware of and comply with the relevant sanctions laws and regulations in their jurisdictions and implement effective compliance programs to mitigate legal hazards.
Some Of The Sanctions Currently Monitored
(a full list is available upon request)
Consolidated Australian Sanctions List
- Consolidated Canadian Autonomous Sanctions List
- EU Financial Sanctions ListJapan Ministry of Finance
- Economic Sanctions List
- Swiss SECO Sanctions List
- UK Sanctions List
- UN Security Council Sanctions
- US OFAC Consolidated Sanctions List
- US OFAC Specifically Designated Nationals (SDN) List
Regulatory enforcement actions lists
- Ireland Disqualified/Restricted Persons List
- Mexico Government Registry of Sanctioned Providers
- Mexico Government Registry of Sanctioned Public Servants
- Mexico SAT Article 69-B Non-Compliance Database
- Russia Legal Entities with Disqualified Executives
- Russian Registry of Disqualified Persons
- US FINRA Barred Individuals
- US HHS LEIE Database
- US SAM.gov Entity Exclusions Database
- Supply chain screening data
- US CBP Withhold Release Orders and Findings Database
- US Department of Commerce BIS MEU List
- US Consolidated Screening List
- US DHS Uyghur Forced Labor Prevention Act List
- US NDAA 1237 List
- US NDAA 1260H List
ADDITIONAL RISK FACTORS
- Forced Labor Risk
- Direct Trade History with WRO Entity
- Direct Trading History with Xinjiang Entities
- Entity Located in Xinjiang
- Keywords Found in Company Attributes
- Owned by Xinjiang-based entity
- Owner of Xinjiang-based entity
- Subtier Trade History with WRO Entity
- Subtier Trading History with Xinjiang Entities
- XPCC ContractorsXinjiang Operations
- Former Sanctions
- Owned by Sanctioned Entity
- Owned by State Owned Enterprise
- Owned by WRO Entity
- Owner of Entity Subject to Regulatory Action
- Owner of Entity in Export Controls List
- Owner of Forced Labor Risk Entity (Xinjiang Import Controls Designation)
- Politically Exposed Person
- Possibly the Same as Entity with Forced Labor Risk (Entity Located in Xinjiang)
- Possibly the Same as Entity with Forced Labor Risk (Xinjiang Operations)
- Possibly the Same as State-Owned Enterprise
- Possibly the Same as a Politically Exposed Person
- Possibly the Same as a WRO Entity
- Possibly the Same as an Entity Subject to Regulatory Action
- Regulatory Action
- State Owned Enterprise
- Related to PEP
- Related to Sanctioned
- Related to WRO Entity
- Terrorism (from Adverse Media)
- Basel AML
- Corruption Perceptions Index
- EU High-Risk Third Countries
