It is a challenging act to correctly implement a restricted and denied party screening process.
Challenges would include the following:
• What is the best timing for the screening?
• Who might be the best person or job function to manage the screening process?
• How to reduce the false positive hits and increase the number of true positive hits?
• How to adjust your searching criteria and what to expect there?
• What to retain as your screening records?
and of course what about the end-use application screening against proliferation risks?
Let’s first talk about the best timing and best responsible people to manage the screening process.
Since the watch lists are subject to frequent changes that are often effective immediately, screening is a repetitive task. The best practices in the industry today recommend three basic approaches in regards to the timing and nature of the screening:
- Partner based screening, where organizations screen of all business partners every time the restricted party lists are updated.
- Transaction-based screening, organizations screen only the relevant business partner(s) prior to each business opportunity and/or transaction.
The third method would be Hybrid screening where both partner screening and transaction based screening employed together. In this method, companies screen all business partners periodically in addition to screening of only relevant business partner(s) prior to each transaction.
The following diagram can be used as a quick reference for possible owners of the screening process in an organization.
Let’s take a look at the section in the left upper corner of the sphere. In a typical supply chain process we would first purchase materials and parts from our suppliers, vendors or subcontractors. As such, we would need to start by screening these companies that we are interacting with. Purchasing and procurement team members would be the one that are the closest to know the suppliers and vendors and to screen these companies. Best timing here would be prior to considering new vendors or submitting a new quote/purchase order request.
Section in the right upper corner shows the transactions with customers and other non-vendor organizations. In case you are dealing with customers, financial institutions and brokers, then the best time for screening would be prior to on boarding them on your customer relationship system and prior to shipping an item, or disclosing software or technology. Customer service and sales team would be the one who can screen these entities.
Let’s say you are hiring new employees, finding a contractor, consultant or agents. Then it is best to screen these individuals before calling them for interviews. If that is not possible then ensure that the individual is screened before he/she is hired.
If you are hosting a visitor in your facility, then the best time to screen their names certainly is before they are accepted to the site and before they are disclosed a controlled technology. Commonly, Human Resources (HR), Security and/or Engineering would be the teams to conduct the screening process.
Finally, in the section located at right lower corner, you will see the interactions with the intermediate and ultimate consignees of the shipments when they are not your direct customers, as well as other entities involved in the shipping process, such as freight forwarders. Since the shipping and logistics personnel are potentially the only ones who are interacting with them, then it makes sense for these personnel to conduct the screening of those entities.
Keep in mind, if you are in a medium and large size company chances are you might already have dedicated trade or export compliance personnel. In many cases, such individuals may manage and coordinate the denied party screening process for the entire company.
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