Restricted Party Screening - Beyond the Consolidated Screening List
May 29, 2020 Author: Heather Noggle, CEO
The practice we call Restricted Party Screening uses many names. Denied Parties Screening. Denied Persons Screening. Entity or Party Background Checks. Regulatory Compliance! The US Federal Government has long published and maintained lists of people and organizations "thou shalt not ship to" and instructed exporters and domestic shippers to ensure compliance in not shipping or obtaining a license. These lists are in various formats and housed in separate websites, and a few years ago the government grouped the data together and called it the Consolidated Screening List.
If you're not fully familiar with the concept of restricted parties screening and its use in Export Compliance, review this web page from the Bureau of Industry and Security about Avoidance of Unauthorized Parties.
Just What is the Consolidated Screening List, and How Do I Use It?
For those who were wearing out reading glasses manually perusing multiple lists for the sake of compliance, the Consolidated Screening List promised to be a great enhancement.
Department of State, Department of Commerce, Department of the Treasury - government IT put data altogether to amalgamate content. Simply plug-in data and get results. Then, conduct your screenings and move on. You could do this all day!
And you might. While there are definite and immediate apparent benefits when applying a comparison of the Consolidated Screening List against manual screening, you'd be undertaking the wrong comparison. Here are some key questions to consider to answer the "why" you mentally supplied to that last statement.
What about other Restricted Persons and Denied Parties lists, other data?
Countries other than the US publish restricted party lists, and the US government itself does as well, and this data isn't incorporated in the Consolidated Screening List. The Consolidated Screening List is incomplete for the needs of international trade; much more data is captured and aggregated in modern Restricted Party Screening software available commercially.
How frequently is the Consolidated Screening List Updated?
We checked - it's 5:00 a.m. daily, Eastern time. Names are added to various lists multiple times a day, meaning at any time other than 5:00 a.m., the Consolidated Screening List lags behind professional Restricted Party Screening providers and their applications.
How do I audit previous screenings performed against the Consolidated Screening List?
The US government doesn't store your screening history - that's something you must do and manage, either manually or automatically. When you're looking to streamline anything, screenshots, and files (paper or electronic) are just a beginning solution. Real-time access to live and historical data available for immediate evaluation is your goal.
How do I properly automate Consolidated Screening List screenings?
The Consolidated Screening List does offer an API with some fuzzy screening, so you can build your own solution to trigger screenings and receive and store results for those screenings. Then, you can build audit selection and storage capabilities to track cleared and held names and addresses. This is clunky and unlikely to be modernized to accommodate your processes.
Here are the technical details: https://www.trade.gov/consolidated-screening-list - review the CSL Application Programming Interface (API) section. Also, https://api.trade.gov/apps/store/#access-to-data-services-and-apis - lots of reading.
These questions and their answers lead to simpler and yet more robust solutions that provide a better return on investment and compliance than manual screening or building partial or full automation yourself against the Consolidated Screening List.
Consolidated Screening List Alternatives - Restricted Persons and Denied Parties Screening Simplified
Automated screening solutions answer the questions posed above, many at attractive price points for small and large companies alike. Here's a review of key features to review beyond the Consolidated Screening List.
Snapshot storage of results for each screening
Each screening acts as a moment-in-time search of the data available at the time of the screening. The name or address screened and the results obtained at the time of screening become an artifact. The same screening 5 days later may yield different results, for example.
Audit capability - storage of data about screenings
Because Restricted Parties Screening software saves screening history and results/settings, audits are easy! Find a previous screening or a person/organization and review dates and times screened. Audit as your process instructs, and save data in the application about your audit.
Modern technology in use! Simpler APIs!
Look for capabilities that clearly enable simple operations.
- Perform a screening and return its results.
- Pull a history of an individual screening or a person or organization screened.
- Audit a specific screening.
These operations and how to undertake them should be very clear, and the application's API should be robust enough to handle any volume at any time of day.
Continuous, not Consolidated
Continuous screening is a possibility! Names previously screened can be checked against new names added to any of the application's managed lists, alerting your company of something to review and clear based on settings of similarity you manage.
Look for a solution that scales to the level of global trade - whatever that is for you - and costs that are reasonable and predictable. Your supply chain processes and managers will thank you. Implementing, automating, and auditing a restricted party screening solution can realize amazing ROI when compared against anything manual. Replace the manual with digital automation and leverage your data to find your truth.
Now, screen us to make sure you can take our advice.