What is a denied party list?
The phrase is used two ways. Narrowly it means the US Denied Persons List, naming parties whose export privileges have been denied. Broadly it means the whole family of restricted-party registers a trade-compliance team screens before a shipment moves.
The ambiguity causes real confusion in scoping. The narrow meaning is the Bureau of Industry and Security's Denied Persons List, whose members have lost export privileges under the Export Administration Regulations. The broad meaning covers sanctions lists, the Entity List, the Unverified List, the Military End-User List and their equivalents in other jurisdictions. Agreeing which one you mean before writing the procedure saves an argument during the audit.
What this workflow covers
SCOPE- Screen the buyer, the ultimate consignee, the end user and the intermediate parties, because controls attach to the transaction chain rather than to the invoiced customer.
- An EU machinery exporter screens the buyer, the freight forwarder and the named end user, and files each result against the shipment reference.
- One party can sit on three registers with three consequences: an export-privilege denial, a licence requirement with a presumption of denial, and an asset freeze.
- A denied-party hit freezes nothing. It stops specified export transactions, which is narrower and just as enforceable.
Compliance glossary
TERMS- Restricted party screening
- Checking every party to a trade transaction against export-control and sanctions registers before shipment.
- End user
- The party that will ultimately receive and use the exported item; export controls turn on end user and end use as well as on the buyer.
Authoritative references
SOURCES- 01Denied Persons List (DPL)
U.S. Bureau of Industry and Security
- 02Entity List (Supplement No. 4 to Part 744 of the EAR)
U.S. Bureau of Industry and Security
Frequently asked questions
Q&A- Denied Persons List or SDN List: who maintains what?
- The Denied Persons List is maintained by the Commerce Department's Bureau of Industry and Security and removes export privileges under the Export Administration Regulations. The SDN List is maintained by Treasury's OFAC and blocks property and prohibits dealings. Different agencies, different statutes, different consequences.
- Which lists does denied party screening usually cover?
- Commonly the BIS Denied Persons List, Entity List, Unverified List and Military End-User List, the OFAC SDN and non-SDN lists, the State Department debarred list, and the EU and UK equivalents. Let the goods, the destinations and your legal nexus set the scope.
- Who has to be screened in an export deal?
- Every party you can identify: buyer, ultimate consignee, end user, intermediate consignees, freight forwarders and, where you know them, the banks. Screening only the invoiced customer leaves the obvious gap.