Due Diligence and Ongoing Monitoring

Hi everyone,

Could someone help me to identify the main restricted lists such as OFAC, UFLPA...? 

Hi Palloma,

I have listed the most common sanctions and blocked persons lists below. U.S. businesses with international customers should work with their compliance team to identify additional requirements to comply with foreign sanctions controls.

1. Specially Designated Nationals and Blocked Persons List (SDN List): The list managed by the U.S. Office of Foreign Assets Control (OFAC) includes individuals and entities that are prohibited from engaging in any type of business or financial transactions with individuals or companies in the United States. This is a measure taken by the U.S. government to enforce economic and trade sanctions against specific individuals and entities for various reasons, such as national security, foreign policy, or anti-terrorism efforts.

2.     U.S. Consolidated Sanctions List: The Office of Foreign Assets Control (OFAC) manages various lists in addition to the Specially Designated Nationals (SDN) list. These additional lists include the Foreign Sanctions Evaders List, Sectoral Sanctions Identifications List, and others.

3.      EU Sanctions List: The European Union meticulously maintains a comprehensive register of restrictive measures targeting countries, organizations, and individuals. These measures are enforced in response to human rights abuses, terrorist activities, and other threats to international security, ensuring a robust framework for maintaining global peace and stability.

4.      UN Sanctions List: The United Nations Security Council uses sanctions to uphold international law and prevent threats to international peace and security. These measures include trade restrictions, financial penalties, travel bans, and arms embargoes. The goal is to compel countries or entities to adhere to international norms and stop activities that endanger global stability. Examples of sanctions are arms embargoes, travel bans, and asset freezes.

5.       The UK Sanctions List: The United Kingdom maintains a list of sanctions designed to target specific individuals and entities, imposing asset freezes, travel bans, and other necessary restrictions for the security and stability of the region.5.

6.      Canada's Consolidated Sanctions List:  Canada has enforced sanctions that involve prohibiting the trade of arms with certain entities, freezing their assets, and imposing limitations on financial transactions with them.

Another list to review is the UFLPA Entity List | Homeland Security (dhs.gov) which contains goods produced or manufactured by entities on the UFLPA Entity List that are made with forced labor and, therefore, prohibited from importation into the United States goods into the United States manufactured wholly or in part with forced labor in the People's Republic of China, especially from the Xinjiang Uyghur Autonomous Region, or Xinjiang.

You may also want to check industry specific lists that contain individuals or entities barred from working in the industry, such as the FDA Blocked and Debarred List for the pharmaceutical industry. Or check with U.S. financial regulators (OCC, FDIC, FED) who also keep list of those entities and individuals under enforcement actions or are prohibited from working in finance.

While these are the most common lists, working with your compliance team to determine the specific lists you should be consulting makes sense. I hope that helps, but I would love to hear from other members.