tradesphere restricted party screening

TradeSphere Restricted Party Screening: User Guide

Last modified: Tuesday, May 1, 2012 Version: TradeSphere Restricted Party Screening v3.0.2.0 This document contains information that is confidential and is the property of Livingston International. It may not be copied, published, or used in whole or in part for any purpose other than as expressly authorized by Livingston International. All trademarks, trade names, and service marks appearing herein are the property of their respective owners. © 2012 Livingston International Inc. All rights reserved.

Livingston International

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TradeSphere Restricted Party Screening User Guide

Table of Contents User Guide Overview .............................................................................................................................1

SUMMARY - USER ROLE .............................................................................................................1 AUDIENCE - USER ROLE .............................................................................................................1

Introduction to Restricted Party Screening.........................................................................................1 OVERVIEW .................................................................................................................................1

Introduction ........................................................................................................................1 Product Nomenclature.......................................................................................................2 Versioning..........................................................................................................................2 Documentation Set ............................................................................................................3

FUNCTIONALITY..........................................................................................................................4 Why Use Restricted Party Screening ................................................................................4 Screening Capabilities.......................................................................................................5 Partner-Screening Events .................................................................................................6 LiveTradeSync Automates Restricted Party List Updates ................................................6 Controlling System Access................................................................................................7

Role Security...............................................................................................................7 Managing Custom Configurations...............................................................................9

POTENTIAL MATCH TYPES ........................................................................................................10 No Potential Match ..........................................................................................................10 The RPL Potential Match.................................................................................................10 The Country Screening Potential Match..........................................................................11 The Unusual Word Potential Match.................................................................................11

WEB-INTERFACE BASICS ..........................................................................................................11 Accessing the Application................................................................................................11 Welcome E-mail and Initial Password .............................................................................12 Logging On to Restricted Party Screening ......................................................................13 Role Home Page .............................................................................................................14 The Restricted Party Screening Work Space..................................................................14

System Menu Bar..................................................................................................... 14 Main Navigation Menu ............................................................................................. 15 The Content Pane .................................................................................................... 15 Maximizing Your Work Space.................................................................................. 16

Updating Your User Profile..............................................................................................17 Updating the General Section.................................................................................. 18 Updating the Personal Information Section ............................................................. 19 Updating the SubOrg Data Section.......................................................................... 20

Changing Your Session Settings.....................................................................................20 Locating Information in Restricted Party Screening ........................................................21

Using Field Filters .................................................................................................... 22 Selecting Dates with the Calendar Icon...........................................................................23

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Logging Off From Restricted Party Screening.................................................................24 EXPORTING A PARTNER'S SCREENING RESULTS TO EXCEL ........................................................25

The Screening Results Excel File....................................................................................25 The Screening Results with Details Excel File ................................................................26

ARCHITECTURAL OVERVIEW - HOSTED IMPLEMENTATION ...........................................................29 Application Architecture...................................................................................................29 Data Archiving .................................................................................................................29 System Maintenance .......................................................................................................30

Actions...................................................................................................................................................30 PARTNER SCREENING...............................................................................................................31

Using the System-Generated ID to Screen a Partner.............................................. 33 Updating and Re-Screening a Partner..................................................................... 33 Using a Customer-Specific ID to Screen a Partner ................................................. 34

Viewing Screening Results..............................................................................................35 Viewing the RPL Match Details................................................................................ 36 Viewing the Country Screening Match Details......................................................... 38 Viewing the Unusual Word Match Note ................................................................... 38

PARTNER SEARCH....................................................................................................................39 Performing Partner Searches ..........................................................................................39 Customizing Partner Searches........................................................................................40 Partner Search Results ...................................................................................................42 Search Results Data Manipulation ..................................................................................44 Using the Search Results - Match Detail Page ...............................................................45

The Screening Details Tab....................................................................................... 46 The Screening History Tab ...................................................................................... 47

Troubleshooting ...................................................................................................................................49 PARTNER SCREENING FAQ ......................................................................................................49

Appendix A - Country Screening Rules .............................................................................................51 COUNTRY SCREENING RULES ...................................................................................................51 ENHANCED PROLIFERATION CONTROL INITIATIVE (EPCI) ...........................................................51

Additional Nuclear Controls .............................................................................................52 ISRAELI BOYCOTT.....................................................................................................................52 US-EMBARGOED COUNTRIES ...................................................................................................53 US-PROSCRIBED COUNTRY LIST ..............................................................................................54 EU-ARMS EMBARGO AND OTHER SANCTIONS............................................................................56

Legal Basis for Imposing Sanctions/Embargoes.............................................................57 UN-ARMS EMBARGO AND OTHER SANCTIONS............................................................................60

Index ......................................................................................................................................................61

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User Guide Overview Summary - User Role

This guide, Working with the Restricted Party Screening User Role, provides instructions on working with the User role in the application; it covers the following topics:

Introduction to Restricted Party Screening

Performing Partner Screenings

Searching for Partner screening records

Viewing the Match Details for previous Partner screenings

Audience - User Role This guide is intended for Restricted Party Screening users who screen Partners for trade compliance purposes; it assumes you are familiar with the following:

Your company's business process for screening Partners.

Using a supported web browser and the associated computer hardware (computer, mouse, and keyboard) that enable web access and online completion of web forms.

Basic Restricted Party Screening navigation and standards.

Note: For basic information about the application, refer to Introduction to Restricted Party Screening on page 1.

Introduction to Restricted Party Screening Overview

The Introduction to Restricted Party Screening provides a general overview of the application functionality including Partner screening, re-screening, and controlling system access.

For the hosted implementation of Restricted Party Screening, the document discusses the architectural overview of the solution at the Livingston International Data Center.

Introduction

For many years, governments around the world have published various entity lists containing government restrictions. These restrictions vary enormously; from an entity with which it is expressly forbidden to have any contact, to an entity that is restricted in trading certain goods, to an entity that might require an export license from the appropriate government.

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In recent years, as a response to a rise in global terrorism and concerns of weapons of mass destruction proliferation, governments have placed trade restrictions on an increasing number of individuals and companies. The United States leads this increased awareness, followed closely by the United Nations, European Union, and other countries, such as Canada and Japan.

In addition to the entity controls, there are trade sanctions and embargoes against entire countries such as the long-running embargo that the United States maintains against Cuba. The United States is the only major economic country to have a restriction against Cuba, and shipping products to Cuba can result in stiff legal penalties against a transgressor.

For companies in the United States, Canada, Japan, and Europe, it has become increasingly difficult to perform the complexities of international business while ensuring that the customer's prospects, suppliers, and distributors (collectively referred to as "Partners") are not subject to restrictions at the entity or country level.

The TradeSphere Restricted Party Screening solution addresses these issues by fulfilling your company's trade screening compliance objectives. For financial institutions, Restricted Party Screening also complies with Section 326 of the USA Patriot Act, which ensures compliance with terrorist screening and anti-money laundering requirements beyond the traditional trade restricted entities lists.

Product Nomenclature

TradeSphere Restricted Party Screening was launched in January 2003. Initially, the product was referred to as "Restricted Party Screening Express" or "RPS Express" in an attempt to capture the product's ease of use and quick deployment – a customer can screen Partners within one day of signing on for the solution.

However, the "Express" portion of the product's name did not accurately communicate the depth of functionality available with the product. The product is based on a solution that has been an integral component of the TradeSphere product suite for over ten years. However, the new product provides enhanced functionality over our embedded solution.

To avoid any confusion, the product was renamed ‘TradeSphere Restricted Party Screening’ or ‘TS RPS’ to refer to the screening solution—both the hosted and non-hosted implementation—that is an integral part of the TradeSphere product suite.

Versioning

The TradeSphere Development Team follows a version numbering system to monitor the major, minor, and maintenance releases of Restricted Party Screening. The current version of the software is TradeSphere Restricted Party Screening v3.0.2.0. The version numbering system is important for non-hosted customers to ensure you have the latest version of the software installed at your site. Livingston International upgrades or migrates hosted customers to new versions of the software, when available.

Note: The TradeSphere Data-Compliance Group publishes updates to the Restricted Party List (RPL) content—the metadata—independent of the software version number of Restricted Party Screening.

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Documentation Set

The supporting documentation for Restricted Party Screening is available through a couple of different avenues:

The Documentation CD: The complete library of documentation is available in PDF format on the accompanying Documentation CD. This allows an Administrator to distribute the documentation to his/her user base outside the application.

Online help directly through the application: You can access the online help in 2 different ways:

− Role Home page: Provides a brief summary of the functionality available to the role along with a link to the online help file for that role.

− Context-sensitive help: Most pages within the application have a link at the top of the page that displays the associated help topic for your current role.

Note: When you access online help within the application, the system restricts

you to the documentation for your current role.

The majority of the supporting documentation is organized according to the functionality available to each role within the application. These documents are the Restricted Party Screening User Guides:

User Guide: Discusses how to screen new Partners, re-screen existing Partners, and perform Partner Searches.

Compliance User Guide: In addition to the topics covered in the User Guide, the Compliance User Guide also discusses how to:

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− Make a screening decision

− Generate and view Restricted Party Screening reports

Internal Compliance Manager Guide: In addition to the topics covered in the Compliance User Guide, the Internal Compliance Manager Guide discusses how to:

− Use the relevant configuration functions (Match, Screening, Integration, Notification, Type, and Work Queue).

− View the Index Configuration settings, Integration History and LiveTradeSync History.

External Compliance Manager Guide: Discusses how to view Restricted Party Screening Activity Summary and how to use the Screening Configuration function.

Client Administrator Guide: Discusses how to:

− Generate and view Restricted Party Screening reports

− View the Activity Summary

− Perform User Administration

System Administrator Guide: Discusses the different aspects of managing the Restricted Party Screening application.

In addition to the Role Guides, the following two documents are included on the Documentation CD:

Using the XML Interface: Provides information on configuring and implementing the XML interface to screen Partners. Topics include submitting the HTTPS request and sending the HTTPS response, and the required XML definition format. The appendices describe SSL/HTTPS security issues and XML connectivity.

Using the Flat-File Interface: Provides information on configuring and implementing the flat-file interface to screen Partners. Topics include submitting the flat-file message using FTP and processing the response message to input into your company's system. The guide provides the required definition format for the flat files.

Functionality

Why Use Restricted Party Screening

In the past, available screening products have provided limited functionality, for example, where the user manually enters individual entities without the ability to load batches of entities, generate reports, maintain an audit trail, or dynamically re-screen existing records against changes to Restricted Party Lists. Solutions with a larger technology footprint, often embedded in Enterprise Resource Planning (ERP) applications with associated higher implementation costs, have not been accessible in a stand-alone configuration.

TradeSphere Restricted Party Screening is a rapidly deployable, robust, and scaleable product serving the entity compliance market. As a hosted solution, Restricted Party Screening ensures that costs are minimized for our users (i.e., no hardware purchases,

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minimal maintenance and administrative costs) while enabling Livingston International to provide the latest compliance data within the product. As a non-hosted product, TradeSphere Restricted Party Screening offers the same functionality as the hosted solution, but your company retains more control over daily maintenance and administrative activities.

Screening Capabilities

The figure below illustrates the Restricted Party Screening process and the various input and output touch points.

When the user submits a screening request, Restricted Party Screening transmits the user's Partner information to the Java-based screening engine. The system enters the Partner details into the Partner database, screens the Partners against the restricted entities, and logs the screening results into an Audit database. The system then returns the results to the user using the same method in which the screening request was received. The possible results that Restricted Party Screening returns are No Match or Potential Match. The system passes all Potential Match Partners to a Work Queue for review by an authorized user. From the Work Queue, the user determines whether the Partner is either:

A Match to one or more of the restricted entities identified by the engine, or

No Match (i.e., a false positive) to any of the restricted entities.

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This process of determining whether a Partner is a "Match" or "No Match" is known as making a "screening decision". Once a user makes a screening decision, the system writes the result to an Audit database.

Partner-Screening Events

Three types of Partner-screening events can occur in Restricted Party Screening:

Manual screening through the web interface.

Partner screening through a text Flat-file or XML message interface.

Re-screening that occurs when you update the RPL database:

− When the system performs a Restricted Party List (RPL) update, it re-screens existing Partner records in the system against the restricted parties contained on the RPL update. The system re-screens Partners with a user or system decision of Potential Match or No Match, and ignores Partners that have been identified as a true Match. The system notifies the appropriate user of any potential matches identified as a result of the update.

− If a potential match is found, the system adds the Partner to the Work Queue. One of the default Work Queues delivered with the application (Update Queue) is configured to hold Partners impacted by an RPL update. Your Client Administrator should ensure that active users are assigned to this Work Queue.

− The value in the Screened By field for Partner screening records identified as a Potential Match as a result of an RPL update is "RPLUPDATE". You can use this value to perform searches or generate reports for Partners impacted by the RPL update process.

LiveTradeSync Automates Restricted Party List Updates

Current Restricted Party List (RPL) content is an integral component of Restricted Party Screening that helps ensure your company’s adherence to compliance mandates.

The TradeSphere Data-Compliance Group (CDG) monitors the supported Restricted Party Lists (RPL) on a daily basis. Occasionally, the CDG adds new names to a list, expires others, or amends address or name information and updates the RPL database.

When enabled, the LiveTradeSync process helps keep your RPL database current by automatically downloading and applying these CDG updates to your Restricted Party Screening environment.

After applying an RPL update, the system automatically screens your Partners against the updated information for potential matches. If a potential match is found, the system adds that Partner to a Work Queue for review.

LiveTradeSync also maintains historical information about the screening results of an RPL update.

If your Administrator configures an e-mail address to receive RPL Update notifications, the system sends an e-mail message to that address following the database update.

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Note: If a previously screened Partner produces a match during a subsequent RPL Update screening, the system sends an XML or flat-file message to the user (depending on the input screening method) in addition to the e-mail notification. The system also sends an e-mail message when it adds a Partner to the Work Queue from an inbound flat-file screening event. The system sends one e-mail message, irrespective of the number of Partners that enter the Work Queue for each flat-file batch. The system does not send a message following one or more hits via XML; the XML response is sent to the client.

Controlling System Access

Role Security

Restricted Party Screening contains six pre-defined roles, which determine a User's access to functionality within the application. The role a person is currently using determines the menu commands available in the Main Navigation menu. A user only sees the menu items to which their role has either update or read-only access.

When you create a User Account for someone in your organization, you assign them the necessary roles (a User Account may be assigned multiple roles). The table below describes the available roles:

Role Name Security Permissions Main Navigation Commands

User Creates and screens Partner records Actions:

Partner Screening Partner Search

Compliance User Same as the User, plus:

Makes screening decisions Generates reports

Actions:

Partner Screening Work Queue Partner Search

Reports:

Generate Reports Report Status

Internal Compliance Manager

Same as the Compliance Manager plus:

Overrides the match decisions made by Compliance Users

Modifies the Match and Screening Configuration

Defines the Escalation, Rationale, and Recommendation values

Manages Work Queues within a company or child SubOrg

Actions:

Partner Screening Work Queue Partner Search

Reports:

Generate Reports Report Status Activity Summary

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Views the Index configuration in a read-only window

Has access to Notification and Integration configuration

Views LiveTradeSync history

System Configuration:

Match Screening Integration Notification Type Index

App Administration:

Work Queue Integration

Monitor LiveTradeSync

History

External Compliance Manager

Configures the following:

Screening Configuration RPL Types

Can also view the Activity Summary

Reports:

Activity Summary


Screening

Client Administrator Administers User accounts.

Can view the following:

The company's Organizational structure (i.e., SubOrg hierarchy)

Integration History LiveTradeSync History

Can also generate and view reports

Reports:


App Administration:

User Organization Integration


History

System Administrator

Configures the following:

Match, Screening, Integration, Notification, Type, and Index settings

TPR_Global.cfg file

Administers the following:

Creates User accounts The company's Organizational

structure (i.e., SubOrg hierarchy) Work queues

Reports:



Match Screening Integration Notification Type Index

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Company administration Performs archive and restore

functions Views the Integration and

LiveTradeSync Histories Configures the RPL Update process

using LiveTradeSync Handles Billing Administration Monitors and troubleshoots the

environment

Can also generate and view reports

App Administration:

User Organization Work Queue Company Archive Archive Status Integration


Admin LiveTradeSync

History Billing Report Billing Report

Status Process View Session Monitor Lock Monitor Task Monitor

Managing Custom Configurations

One of the key design features of Restricted Party Screening is the SubOrg parent/child hierarchy. In this relationship:

The parent SubOrg resides one level above its child SubOrg(s).

By default, child SubOrg(s) inherit the various configuration settings from the parent SubOrg. The configuration settings of the parent "cascade" down the tiers of your company's hierarchy.

If necessary, you can break this chain of inheritance anywhere in your schema to customize the configuration of an individual SubOrg in your hierarchy.

When you customize the configuration settings for a particular SubOrg, all its child SubOrgs (and other decedents) inherit the new configuration.

The key benefit of the parent/child hierarchical relationship is that it allows you to leverage pre-existing rules in your workflow where appropriate, while allowing you to customize configuration settings when necessary.

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Potential Match Types The RPL Engine identifies Potential Matches using the following four criteria:

Potential Match Criteria

Description

No Match The submitted Partner data does not produce a Potential Match to any of the following:

An RPL restricted entity A Country Screening rule An Unusual Word from the Unusual word Dictionary

For details, refer to No Potential Match on page 10.

RPL The submitted Partner data matches one or more restricted entities on the configured RPL lists. For details, refer to The RPL Potential Match on page 10.

Country Screening

The submitted Partner data matches one or more of the configured Country Screening rules. For details, refer to The Country Screening Potential Match on page 11.

Unusual Word The submitted Partner data matches one or more words in Unusual Word Dictionary. For details, refer to The Unusual Word Potential Match on page 11.

No Potential Match

When a Partner Screening does not produce a Potential Match, the system:

Displays the following message on the Screening Results page: No Potential Matches found.

Places the following note on the screening record: "No Potential Matches found". The note includes the user ID of the person performing the screening and the time-stamp of the screening.

The RPL Potential Match

The majority of Potential Match hits in Restricted Party Screening are the result of the system matching the Partner Screening data to one or more entities on the RPL lists.

When an RPL Potential Match occurs, the system displays the:

Match score for the Partner information submitted for screening

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Matching Details for the current screening in the Matching Details section of the Screening Details tab

For additional information, refer to Viewing the RPL Match Details on page 36.

The Country Screening Potential Match

Restricted Party Screening allows your company to customize the country rules against which the RPL Engine screens Partners.

Country Screening rules can be customized at the SubOrg level.

The available rules are:

EPCI - US Enhanced Proliferation Control Initiative restricted countries

Anti-boycott - US anti-boycott practices against Israel

US Embargo - US list of countries subject to US sanctions and embargoes

UN Embargo - UN list of countries subject to UN sanctions and embargoes

EU Embargo - EU list of countries subject to EU sanctions and embargoes

Proscribed US Proscribed countries (ITAR 126.1)

For additional information, refer to Country Screening Hits in the Work Queue. on page 38

The Unusual Word Potential Match

Restricted Party Screening allows your company to create an Unusual Words Dictionary. The Unusual Words Dictionary is a collection of words that are so alarming that any query phrase containing one or more of the unusual words is automatically flagged and is brought to the attention of a decision maker. Possible candidates for the Unusual Words Dictionary could be: nuclear, missile, chemical, etc.

Note: Modifications to the Unusual Words Dictionary are made by the Internal Compliance Manager role via the Match command.

For additional information, refer to Viewing the Unusual Word Match Note on page 38.

Web-Interface Basics

Accessing the Application

Restricted Party Screening is a web-based application that supports the following browser:

Microsoft Internet Explorer™ v6.0, v7.0 and v8.0

Note: Older versions of Internet Explorer may display pages erratically. TradeSphere does not officially support other web browsers, such as Firefox, Opera, and Chrome.

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To access the application, enter the appropriate URL into your browser:

Hosted Solution: If Livingston International hosts Restricted Party Screening for your company, go to Livingston’s web portal, TradePrism.com (https://www.tradeprism.com).

Non-hosted Solution: If your company hosts the Restricted Party Screening application, the URL to access the application has the following format:

http://{ServerName}/TP/RPS/RPSDesktop/rps.jsp

(Where: {ServerName} is the server on which Restricted Party Screening is installed).

When you initially access the application, the Login page displays.

Note: For quick future access to Restricted Party Screening, bookmark the Login page.

Welcome E-mail and Initial Password

Your Client Administrator or System Administrator adds new users to Restricted Party Screening. When you are added as a new user, the system sends you an e-mail with the Subject "Welcome to Restricted Party Screening". The e-mail provides the following information:

Your User ID

Your temporary password

The application's URL

If your e-mail program is configured to receive HTML e-mail, click the URL to access Restricted Party Screening.

If your e-mail program displays e-mail as text, copy and paste the URL into your browser to access Restricted Party Screening.

When logging in to the application for the first time, you will be prompted to select a new password. Your new password must meet the following requirements:

Password length: 7 to 20 characters

Valid characters: A-Z, 0-9, space, underscore (_), hyphen (-)

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Logging On to Restricted Party Screening

Before accessing Restricted Party Screening, you must enter your User ID and Password on the Login page.

If you provide an invalid User ID or Password, the following error message displays in red font on the page:

"The login information you provided does not match our records. Please try again".

If you can not recall your password, click the Forgot Password link to send an e-mail containing your password to the e-mail address stored in your User Profile. For more information on updating your User Profile, refer to Updating the General Section on page 18.

After three incorrect login attempts, your User account is locked. The following error message displays:

"Your User Account (<User_ID>) is disabled. Please contact your Client Administrator for assistance".

(Where <User ID> is your Restricted Party Screening User ID).

When you lock your account, contact your Client Administrator to unlock it. Click the Client Administrator link in the lock message to notify your Administrator by e-mail.

If you provide valid login credentials, the Role Home page for your default role displays.

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Role Home Page

The Role Home page for your default role displays once you have successfully logged into Restricted Party Screening.

Each role in the application has a Role Home page that provides a brief summary of the functionality available to the role along with links to the online help for that role.

The Restricted Party Screening Work Space

The Restricted Party Screening work space contains three sections:

System Menu Bar: Provides access to your current session settings.

Main Navigation Menu: Provides access to the functional commands within the application.

Content Pane: Displays the page(s) associated with the application commands.

System Menu Bar

The System Menu Bar provides access to your current session settings along with links to access the My Profile page and to log off the application.

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The following table contains information on the fields comprising the System Menu Bar:

Field Description

User Read-only field that displays your User ID.

Company Read-only field that displays your Company name.

SubOrg Displays your current SubOrg. Use the drop-down to select another SubOrg to which you have access.

Role This field displays your current Role. Use the drop-down to select another Role to which you have access.

Main Navigation Menu

The Main Navigation Menu lists the functional commands available to your current role. You select a command with a single left-click of your mouse. When you select a command, the corresponding page displays in the Content Pane.

Note: The commands you see on the Main Navigation menu are determined by your current role. If you do not see a command to which you know you have access, you need to change your current role. You change your role using the System Menu Bar Role drop-down. For a list of commands available under each role, refer to Controlling System Access - Role Security on page 7.

The Content Pane

When you select a command, the corresponding page displays in the Content Pane. You use this area of the Restricted Party Screening work space to interact with the application (e.g., to complete a field, set a configuration value) and to view the results returned by the system.

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Maximizing Your Work Space

You can maximize the Restricted Party Screening work space to accommodate more information on the viewable screen by collapsing the Main Navigation menu using the Minus icon located in the upper left section of the screen.

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Once hidden, click the Plus icon to expand the Main Navigation menu again.

Updating Your User Profile

Use the My Profile link, located in the System Menu bar, to change your personal information in the application.

The My Profile page contains three expandable/collapsible sections:

General

Personal Information

SubOrg Data

Each section title of the My Profile page displays as a link in white font against a blue background. The default view of the page displays the General section with the other two collapsed. To view one of the other sections, simply click its name.

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Updating the General Section

Use the General section to input and maintain your basic User Account information.

The following table describes the fields in the General section:

Field Description

User ID Displays your User ID. This field is read-only; the User ID can not be updated.

Name Displays your current name. You can update your name in the application using this filed.

Email Displays your current e-mail address. You can update your e-mail address using this field. The system uses the address in this field to send automated notifications to you.

Password Displays your current password. For security reasons, the system masks the password with asterisks. You can update your password using this field.

Passwords must be between 7 to 20 characters in length. Valid password characters include A-Z, 0-9, spaces, underscores

(_), and hyphens (-).

Re-enter Password

Displays your current password. For security reasons, the system masks the password with asterisks. When you update your password you must confirm the new password using this field.

All fields in this section are required. When you click Save, the system validates the data:

If the information passes validation, the system saves your User Account record and displays the following message in the Status Bar:

"Save completed successfully!"

If any information is missing, the system:

− Displays the following message in red font at the top of the page:

"Please input the highlighted mandatory fields".

− Highlights the relevant field(s) names in red font, and highlights the input section in yellow.

If the Password and Re-enter Password fields do not match, the following message displays the following pop-up message:

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"The passwords you have entered do not match. Please enter matching passwords. Please input the highlighted mandatory fields".

Updating the Personal Information Section

Use the Personal Information section to input and maintain work-related information.

The following table describes the fields in the Personal Information section:

Field Description

Title Displays your current title. You can update your title using this field. The Title field is optional.

Address 1 Displays line 1 of your current address. You can update line 1 of your address using this field. The Address 1 field is optional.

Address 2 Displays line 2 of your current address. You can update line 2 of your address using this field. The Address 2 field is optional.

City Displays your current city. You can update your city using this field. The City field is optional.

Country Displays your current country. You can update your country using this field. The Country field is optional.

Phone Displays your current phone number. You can update your phone number using this field. The Phone field is optional.

Fax Displays your current fax number. You can update your fax number using this field. The Fax field is optional.

Default Locale

Displays your current Default Locale value from the drop-down list.

The first character of the Default Locale drop-down relates to your language. Examples: "en" for English, "es" for Spanish.

The second character relates to the country. Examples: "US" for United States, "MX" for Mexico.

You can update your Default Locale using this field. The Default Locale

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Field Description

field is optional.

Time Zone Displays your current Time Zone. The Time Zone drop-down list consists of Java™ standard time zones, not Microsoft™ standard time zones.

You can update your Time Zone using this field. The Time Zone field is optional.

Updating the SubOrg Data Section

Use the SubOrg Data section to change your default SubOrg or role.

To change your default SubOrg:

1. Click the default radio button for the corresponding SubOrg.

2. Click the Save button. The system displays the following message in the browser Status Bar:


To change your default role:

1. Click the default radio button for the corresponding role.

2. Click the Save button. The system displays the following message in the browser Status Bar:


Changing Your Session Settings

The System Menu Bar displays your current session settings.

If you have access to more than one SubOrg or Role, you can change these settings from the System Menu Bar drop-down lists. To change a session setting, select the appropriate value from the corresponding drop-down list.

Example:

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Use the Role drop-down list to change your SubOrg setting for the current session.

The following table provides information on the System Menu Bar elements:

Element Description

SubOrg A SubOrg represents an entity, division or other logical division within your organization. When you select a SubOrg, the system limits your access to those records assigned to that SubOrg. Also, when you create records, the system assigns them to your current SubOrg.

If your company uses multiple SubOrgs and your Client Administrator or System Administrator has granted you access to more than one of them, select the appropriate SubOrg using the System Menu Bar SubOrg drop-down.

Note: To maintain data integrity and security within Restricted Party Screening, you cannot remove a SubOrg from the system. Livingston International creates and maintains SubOrgs on a fee basis. See your account executive for more information.

Role A Role is a collection of security permissions that grant access to functionality within the application. Roles are defined to support users who share the same job functions. Roles are pre-defined and cannot be modified. Your ability to access commands and SubOrgs changes based on the security settings of your current Role.

The Client Administrator or System Administrator assigns roles. If you have access to more than one Role, you can change your Role using the System Menu Bar Role drop-down.

Locating Information in Restricted Party Screening

Restricted Party Screening provides two easy-to-use tools for obtaining summary or detailed information about your company's screening activity:

Partner Search: Use to locate records within the application

Reports: Use to obtain information outside the application

Note: Users whose business role requires access to information regarding the application's data should be assigned a role with access to reporting functionality.

Both tools provide a collection of filters that allow you to quickly retrieve the specific information you require.

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Note: The Partner Search functionality, used in conjunction with the Restricted Party Screening reports, is an effective auditing tool.

Using Field Filters

Field filter drop-down menus are available on both the Search and Generate Reports pages.

Field filter drop-down menus provide the following functionality:

Select a value: Click the individual value. The corresponding check box is selected.

Clear a previously selected value: Click the value again. The corresponding check box is deselected.

Select multiple values: Continue to click the required values. The corresponding check boxes are selected.

Select all values: Click Select All at the bottom of the drop-down list. All check boxes are selected.

Clear all your selections: Click Clear All at the bottom of the drop-down list. All check boxes are deselected.

Enter your selection: Click OK at the bottom of the drop-down or click out of the drop-down list. Your selections display in the input field, separated by semicolons.

To cancel your selection, click Cancel at the bottom of the drop-down list. None of your selections display in the input field.

In addition, most field filters also provide a parameter drop-down menu to allow you to further refine your results based on the value(s) selected from the drop-down menu.

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The parameters available for an individual field depend upon the information stored in that field. The following table provides details on the field filter parameters available:

Filter Parameter

Description

Before Retrieves records earlier than the date you entered in the associated field.

After Retrieves records later than the date you entered in the associated field.

Between Retrieves records between the dates you entered in the associated fields.

Contains Retrieves those records where the associated field contains the alphanumeric characters you specify. The characters can appear anywhere within the field.

Equals Retrieves those records where the associated field exactly matches the string of alphanumeric characters you specify.

Not Equals Retrieves those records where the associated field does not match the string of alphanumeric characters you specify.

Starts With Retrieves those records where the associated field starts with the alphanumeric characters you specify.

Ends With Retrieves those records where the associated field ends with the alphanumeric characters you specify.

Selecting Dates with the Calendar Icon

Dates in Restricted Party Screening must be formatted as follows: MM/DD/YYYY.

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If you do not enter a date in the proper format, the system displays a pop-up reminding you to use the proper format.

You can avoid date formatting errors by using the Calendar icon ( ) to select a date.

To use the Calendar icon:

1. Click the Calendar icon ( ) corresponding to the field to which you want to provide a date value. The Calendar window displays the calendar for the current month with the current date highlighted.

Note: To change the day that the calendar week begins (Sun - Sat), click the name of the day you want to move to the beginning of the week.

2. Select the appropriate date:

− To choose the current date, click Today or the days date in the calendar.

− To choose another date in the current month, click the number corresponding to the required date.

− To choose a date outside of the current month use the following buttons:

Icon Description

<< Controls which year the calendar displays: Click to move sequentially through previous years. Click and hold to display a drop-down of previous years.

< Controls which month the calendar displays: Click to move sequentially through previous months. Click and hold to display a drop-down of months in a calendar year.

> Controls which month the calendar displays: Click to move sequentially through next months. Click and hold to display a drop-down of months in a calendar year.

>> Controls which year the calendar displays: Click to move sequentially through future years. Click and hold to display a drop-down of future years.

Logging Off From Restricted Party Screening

To log off from Restricted Party Screening, click the Log Off link located in the upper right section of all pages.

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Exporting a Partner's Screening Results to Excel You can export the RPL Screening Results to an Excel file on the following pages:

Screening Results: The file contains the Match Details for the currently Partner Screening.

Search Results - Match Detail: The file contains the Match Details for the individual Partner screening record you are currently reviewing.

Work Queue: The file contains the Match Details for all the Partner screening records in your Work Queue.

Work Queue Details: The file contains the Match Details for the individual Partner screening record you are currently reviewing.

To generate the file, click an Export to Excel link.

There are two export options available:

Export to Excel: Generates an RPL Screening Results file. For details on the information contained in the file, refer to The Screening Results Excel File on page 25.

Export to Excel with Details: Generates an RPL Screening Results with Details file. For details on the information contained in the file, refer to The Screening Results with Details Excel File on page 26.

The Screening Results Excel File

You can export the RPL Screening Results to an Excel file by clicking the Export to Excel link.

When you click the link, your browser displays a pop-up that prompts you to view the file, save it or cancel the request.

Note: If you need the Match Details for the Partner screenings, select the Export to Excel with Details instead.

The following fields comprise the RPL Screening Results Excel file:

Field Description

Seq The unique system-assigned number identifying each Partner record in the report.

SubOrg The SubOrg to which the Partner belongs.

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Field Description

Partner ID The unique Restricted Party Screening identifier associated with the Partner record.

Partner Type The Partner Type of the Partner record.

Partner Name The Partner's name (individual and/or company name).

Partner Address The Partner address, as reflected in your company's records.

Rationale The justification for the screening decision based on the Partner's appearance on any of the denied party lists.

Recommendation The suggested actions based on the screening decision.

Escalation The Escalation designation for the Partner record.

Screened By The User ID of the individual who performed the initial screening.

Screened Date The date the Partner was last screened.

Decision The current decision for the Partner:

PENDING– The Partner appears in the Work Queue; the system determined that the Partner matches a restricted entity, but a user must make the final decision.

NO MATCH– The Decision By user determined the Partner does not match a restricted entity.

MATCH– The Decision By user determined the Partner is a restricted entity.

Decision By The User ID of the individual who made the screening decision or SYSTEM for a system-generated match.

Decision Date The date the screening decision was made.

Notes Any notes appended to the Partner record as part of the decision-making process.

The Screening Results with Details Excel File

You can export the RPL Screening Results with Details to an Excel file by clicking the Export to Excel with Details link.

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When you click the link, your browser displays a pop-up that prompts you to view the file, save it or cancel the request.

Note: You can use this file to send Partner screening records for review to people in your company without Restricted Party Screening access.

The following fields are contained in the RPL Screening Results with Details Excel file:

Field Description

Seq The unique system-assigned number identifying each Partner record in the report.


Partner ID The unique Restricted Party Screening identifier associated with the Partner record.

Partner Type The Partner Type of the Partner record.

Partner Name The Partner's name (individual and/or company name).

Partner Address The Partner address, as reflected in your company's records.

RPL Type The list in which the restricted entity citation was published.

Published Date The date the entity appeared in the government publication. Use this date to search the relevant regulatory web sites to locate the full citation entry for an entity.

Effective Date The specific start date for the legislation against an entity. Use the Effective Date to determine the status of a Partner/entity match.

Expiration Date The specific end date for the legislation against an entity.

Many entities are placed on restricted lists for a specified period of time. If an expiration date is not specified in the issuing legislation, the system sets a default Expiration Date of 31-Dec-2078.

Page The page number of the citation.

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Field Description

Volume The volume number of the list in which the citation appears.

Name Match Score

The probability that the Partner's name is a match to the restricted entity name. A higher score indicates a greater chance of a match. A score of 1.00 indicates a perfect match probability, while 0.00 indicates no match.

Note: The engine considers several factors when calculating the Match Score, including the number of words entered, the number of letter differences between the Partner and the entity, and the weighting of different algorithms used in the match engine.

Match Name The name of the entity (including all aliases) that potentially matched the Partner (the Match Score for the aliases that were not potential matches should be 0.0).

Address Match Score

Refer to the Name Match Score description above.

Match Address Displays information if the Partner potentially matched an entity based on address. Multiple addresses indicate alternative spellings for the entity address that matched the Partner.

Rationale The justification for the screening decision based on the Partner's appearance on any of the denied party lists.

Recommendation The suggested actions based on the screening decision.

Escalation The Escalation designation for the Partner record when the decision was rendered.

Screened By The User ID of the individual who performed the initial screening.

Screened Date The date the Partner was last screened.


POTENTIAL MATCH– The Partner appears in the Work Queue; the system determined that the Partner matches a restricted entity, but a user must make the final decision.

NO MATCH– The Decision By user determined the Partner does not match a restricted entity.

MATCH– The Decision By user determined the Partner is a restricted entity.

Decision By The User ID of the individual who made the screening decision or SYSTEM for a system-generated match.

Decision Date The date the screening decision was made.

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Field Description

Notes Any notes appended to the Partner record as part of the decision-making process.

Architectural Overview - Hosted Implementation

Application Architecture

The figure below illustrates the application architecture of the hosted implementation of the Restricted Party Screening solution. Livingston International hosts the application at our Data Center in Reston, Virginia, USA, using a secure HTTPS environment that utilizes encryption to prevent unauthorized access to your data. The application supports web access as well as an API using ASCII flat-files and XML data. The data center uses The Apache TomCat application server, an IBM HTTPS web server, Livingston’s JSP Servlet engine for processing code, and the Java-based Restricted Party Screening engine to perform the matching. All databases currently use Oracle 11g.

Data Archiving

Important: Within the United States and European Union, the statutory requirement for maintaining an audit trail of compliance decisions is five and seven years

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respectively. The hosted Restricted Party Screening solution maintains a complete history of all screenings, including those that occurred over seven years for legal liability purposes.

As users submit Partner information, the system stores the data in Livingston’s hosted databases. The stored data consists of Partner information, match results, notes, and other information used for auditing. For the majority of customers, the data increases at a relatively low rate and never becomes a strain on resources. However, in some cases (e.g., customers passing more than 10,000 Partners to the system each day), the databases can reach very large sizes quickly. As a result, archiving of older database records may be necessary.

Restricted Party Screening uses the Oracle Export and Import utilities to archive and restore data. During the archive process, the data is compressed and stored in an archival database. Your company does not experience any interruption of service during an archive. Once records are archived, you cannot generate reports on the archived data.

Hosted Clients:

The TradeSphere Support Group archives data when:

− An individual hosted client's data limits system resources. In this event, the TradeSphere Support Group contacts the affected client to explain the archival process and when it will occur.

Note: In some cases, Livingston International might archive historical audit records that are more than 5- or 7-years old depending on the statutory limits for the client's business and to gain application efficiencies. This activity preserves the recent historical screenings and Partner information so it is subject to future RPL updates.

− A client's account expires or a client terminates the account with no clear indication of pending renewal of the relationship.

− A client requires screening data for an external audit. Contact your account executive for information on archiving your data in whole.

Non-Hosted Clients:

Livingston International strongly recommends that your company develops an archive strategy to suit your business needs. TradeSphere implementation consultants can work with you to identify the optimal solution.

System Maintenance

Livingston International reserves a weekly maintenance window every Saturday at 10:00 p.m. to Sunday 1:00 a.m. Eastern Standard Time. If there is maintenance work to perform, the TradeSphere Support Group notifies customers 48 hours in advance of the maintenance. If the work will extend beyond the maintenance window, the TradeSphere Support Group notifies customers seven (7) days prior to the start of the work.

Actions

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Partner Screening The following roles can perform Partner screenings in Restricted Party Screening:

User - the User role can perform Partner screenings, but cannot make a decision based on them, as the Decision, Recommendation, Rationale, Escalation, and Notes fields are read only.

Compliance User - the Compliance User role can perform Partner screenings, save the screening results and make a decision based on them.

Internal Compliance Manager - although the Internal Compliance Manager role can perform screenings to tune the Restricted Party engine, it cannot save the screening results or make a decision based on them. However, the Internal Compliance Manager does have access to the Explain Results pages, which provide details on the parameters the Restricted Party engine used to establish the name-pair match between your Partner and the restricted entity in its current configuration. The Internal Compliance Manager uses this information to tune the Restricted Party Screening engine.

The Partner Screening command displays in the Main Navigation menu only for these roles.

To screen individual Partners, access the Partner Screening page:

To screen a Partner from the Partner Screening page:

1. Click the Partner Screening command. The Partner Screening page displays.

2. Enter the Partner's information in one or more of the following fields:

Fields Description

ID The unique identifier for a Partner record. By default, the system generates a new ID each time the page is accessed. You can use the system-generated ID or enter another value in the ID field.

Note: You must enter a unique ID. If the ID exists in the

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Fields Description

database, the system retrieves the Partner data for the existing ID.

For more information on using the ID field, see Using the System-Generated ID to Screen a Partner.

Type Describes the role a Partner plays in a transaction.

Important: This field is not part of the screening process and is generally not used for manual screenings. The Partner Type field supports other TradeSphere products (e.g., TradeSphere Exporter) and is made available to filter Partner search and report results.

Name The individual or company name of the Partner. For best results, supply as much detail as possible.

Address 1 Address 2 Address 3 Address 4 Address 5

The street, suite, apartment number, district or other components of an address not covered by City, State, Postal Code or Country.

City The name of the city, town, or village for the postal destination.

State The full name of the state, province, county or other geographical boundary.

Note: Do not use the two- or three-letter code for the State; use the full name, for example, Virginia.

Postal Code

The Postal Code for the Partner's address.

Country Code

The code of the country in which the Partner resides or from which the Partner is based.

For best results, use the Country Name field when screening to ensure compliance for sanctioned and embargoed destinations.

Select a country from the drop-down.

Country Name

The country in which the Partner resides or from which the Partner is based.

For best results, use either the Country Code or Country Name to ensure compliance for sanctioned and embargoed destinations.

Select the value(s) from the drop-down or manually input the information.

3. Click Screen to screen the Partner information. The results display on the Screening Results page.

Note: To reset all fields on the page, click Clear.

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Using the System-Generated ID to Screen a Partner

In most situations, the following is the standard method of screening Partners:

1. Click the Partner Screening command on the Main Navigation menu. The Partner Screening page displays with a system-generated ID in the ID field.

2. Enter the Name and Address information if available. Enter the Country to enable the Country-screening Rules if configured to run at your site.

Note: Refer to Screening Individual Partners for details on the fields comprising the Partner Screening page.

3. Click Screen. The engine attempts to locate matches in the database of restricted entities. The results display on the Screening Results page.

Updating and Re-Screening a Partner

Important: When you modify and manually re-screen a Partner, the system updates the existing database record for the Partner with your modifications.

To update a Partner's information in Restricted Party Screening, and then re-screen the Partner based on your changes, use the following steps:

1. Locate the screening record for the Partner:

a. If you know the ID of the Partner record in the application: • Click the Partner Screening command on the Main Navigation menu. The

Partner Screening page displays with a system-generated ID.

• Enter the Partner ID in the ID field, overwriting the system-generated value.

• Enter the Type value for the Partner only if the Partner has a value other than the default "ANY". The system retrieves the existing Partner record.

• Proceed to step 2.

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b. If you do not know the ID of the Partner record in the application: • Click the Partner Search command on the Main Navigation menu. The

Partner Search page displays.

• Complete one or more of the Search fields (e.g., Partner Name, Screened

Date) to locate the Partner record.

• Click Search. The Partner record displays on the Search Results page.

• Click the Check Mark icon ( ) to move the record to the Partner Screening page.

• Proceed to step 2.

Note: You can review the current screening Match Details prior to re-screening

by clicking the Details icon ( ).

2. Update the Partner information as necessary.

3. Click Screen. The engine attempts to locate matching details in the database of restricted entities.

Using a Customer-Specific ID to Screen a Partner

To use your company's internal ID to screen a Partner (e.g., the ID your company uses to reference the Partner in your order entry system or other ERP application), use the following steps:

1. Click the Partner Screening command on the Main Navigation menu. The Partner Screening page displays with a system-generated ID in the ID field.

2. Overwrite the system-generated ID with your company's ID.

Note: You must enter a unique ID. If the ID already exists in the database, the system retrieves the Partner data for the existing ID.

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3. Enter the Name and Address information, if available. Enter the Country to enable the Country-screening Rules if configured to run at your site.

Note: Refer to Screening Individual Partners for details on the fields comprising the Partner Screening page.

4. Click Screen. The system attempts to locate matches in the database of restricted entities. Results display on the Screening Results page.

Viewing Screening Results

Use the Partner Screening Results page to review the screening results and select a decision for the Partner.

The page is organized into the following sections:

Partner Information: Contains the Partner Name and Address information screened by the application and, for RPL matches, the resulting Match Score. To the right of the Match Score, on the same row, is an Export to Excel link to save the Match Details for this screening to an Excel file. For details refer to The Screening Results with Details Excel File on page 26.

Decision: Contains the current decision of the Partner screening and the fields to make a final screening decision. For the User role, this section is read-only.

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Match Details: Contains information explaining why an RPL match occurred and the implications of the match. For the User role, this section is read-only. For details, refer to Viewing the RPL Matching Results on page 36.

Country Screening: Displays a warning message when a Partner screening results in a Country Screening Potential Match. The message provides the Country Screening rule that triggered the Potential Match status and provides links to additional information. For details, refer to Viewing the Country Screening Match Details on page 38.This section only displays for Country Screening Potential Matches.

Buttons: The following buttons are found at the bottom of the page:

− Modify Partner: Displays the Partner Screening page to modify Partner information and rescreen.

− Save Results: Writes Match and No Match decisions to the database (for roles that can make decisions) or saves the record as a Potential Match to the Work Queue for making future decisions (for roles with screening authority). This button does not display for the Internal Compliance Manager.

Viewing the RPL Match Details

The Match Details section appear on both the Screening Details and Screening History tabs. Use the Match Details section to understand why an RPL Potential Match occurred and the implications of the match.

Entries are formatted in alternating white and blue rows.

The following table provides information on the different fields in the Match Details section.

Field Description

# A sequence number that identifies each restricted entity match in the list.

RPL Type The list containing the restricted entity. The application may display several entities with the same Name and/or Address but with a different RPL Type. This is often the case with global terrorists who appear on several different government lists.

Use the RPL Type link to:

View a description of the Restricted Party List (RPL) including the government agency to which the list belongs.

Send questions regarding the RPL list to Livingston’s Compliance Data Group.

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Field Description

Visit the supporting governmental web site.

Note: The URLs in the RPL Type links are subject to change without notice; the linked content is not maintained by Livingston International.

Name Displays the potential matches of the input Partner to an entity based on Name. Additional names, which may superficially appear unrelated, may also display. These names are alternate spellings of, or Also Known As (AKA) designations, for the restricted entity.

Name Score

The probability that the Partner's name is a match to the restricted entity name. A higher score indicates a greater chance of a match. A score of 1.00 indicates a perfect match probability, while 0.00 indicates no match.

Note: The engine uses several factors to calculate the score, including the number of words entered, the number of letter differences between the Partner and the entity, and the weighting of different algorithms.

Address Displays the potential matches of the input Address to an entity based on Address. If the system displays multiple Addresses, they are alternative spellings for the entity Address that matched the input Partner.

Address Score

Refer to the Name Score description above.

Published Date

The date the entity appeared in the governmental publication corresponding to the RPL Type. Use this date to search the relevant regulatory web sites to find the full citation entry for an entity.

Effective Date

The specific start date for the legislation against an entity, if applicable. Use the Effective Date to determine the status of a Partner/entity match.

Expiration Date

The specific end date for the legislation against an entity.

Many entities are placed on restricted lists for a specified period of time. If an expiration date is not specified in the issuing legislation, the system sets a default Expiration Date of 31-Dec-2078.

Citation The reference code used on a regulatory web site. Use the Citation to find the full citation entry for an entity associated with the Published Date.

For US Federal Register citations, the citation is usually the volume followed by page number (for example 66: 34676). Other citations are in the relevant format for the issuing source. Occasionally, an entity's restricted status is amended by subsequent legislative publications. Any historic citations are listed as well.

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Viewing the Country Screening Match Details

When a Partner Screening produces a hit on a Country Screening rule, the system notifies you of this fact, by displaying the following message in the Country Screening section:

Warning: <Partner_Country> is subject to <Country_Screening_Rule> restrictions. The address for this partner is located in <Partner_Country> and may be subject to additional restrictions. Further due diligence is required to determine if these restrictions are applicable to this partner or any transactions associated with this partner. For more information on country rules, click on the link(s) above, or refer to the appendix within the user documentation.

Where:

− <Partner_Country> is the name of the country that triggered the Potential Match.

− <Country_Screening_Rule> is the name(s) of the Country Screening rule(s) causing the Potential Match. The Country Screening rule names are links to additional information regarding the rule located in Appendix A.

This system also displays the following message in the Existing Notes field along with the user ID of the person performing the screening and the time-stamp of the screening:

This partner was flagged because <Partner_Country> is subject to <Country_Screening_Rule> restrictions.

For additional information, refer to The Country Screening Potential Match on page 11.

Viewing the Unusual Word Match Note

Restricted Party Screening allows your company to create an Unusual Words Dictionary. The Unusual Words Dictionary is a collection of words that are so alarming that any query phrase containing one or more of the unusual words is automatically flagged and is brought to the attention of a decision maker. Possible candidates for the Unusual Words Dictionary could be: nuclear, missile, chemical, etc.

Note: Modifications to the Unusual Words Dictionary are made by the Internal Compliance Manager.

When a Partner Screening produces a hit on a word in your Unusual Words Dictionary, the system notifies you of this fact in two different ways on the Partner Screening Results page:

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The system places a note in the Note field on behalf of the person performing the screening. The note states:

***IMPORTANT***

This partner was flagged because it contains one or more UNUSUAL words.

In the Match Details row, the system displays the following message in yellow font:

This Partner Contains One or More UNUSUAL Words.

Important: The system-generated Unusual Word note is the only indication as to why the Partner Screening record was flagged a "Potential Match" when it displays in a Work Queue.

For additional information, refer to The Unusual Word Potential Match on page 11.

Partner Search

Performing Partner Searches

Note: The Partner Search functionality, used in conjunction with the Restricted Party Screening reports, is an effective auditing tool.

To locate a record in the Restricted Party Screening Partner database:

1. Click the Partner Search command from Main Navigation menu. The Partner Search page displays.

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2. Customize your search using the numerous filters available on the page. Refer to Customizing Partner Searches for details.

Note: Click Clear to reset the input parameter fields to their default settings.

3. Click Search to perform your search. The search results display on the Partner Search Results page.

Customizing Partner Searches

The Partner Search page contains numerous filters to customize the search criteria for your company's screening activity. Click the Partner Search command from the Action section of the Main Navigation menu to access the Partner Search page.

For instructions on using the drop-down menus to specify your search filters, refer to Using Field Filters on page 22.

The following table provides information on the fields comprising the Partner Search page:

Fields Description

SubOrg Search for Partner records in your current SubOrg. The drop-down defaults to your current SubOrg and contains all child SubOrgs within your current SubOrg.

Note: To retrieve a list of all current records in a SubOrg, select the SubOrg, leave all other fields blank, and click Search.

Include Child SubOrgs

Select this check box to include all SubOrgs within the selected SubOrg(s) in the search results. The check box is selected by

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Fields Description

default if a SubOrg has children.

Partner Type Refine your search based on Partner Type. Enter the Partner Type in the field.

Note: This field is not case sensitive.

Partner ID Refine your search based on Partner ID. Enter the Partner ID in the field.


Partner Name Refine your search based on Partner Name. Enter the Partner's Name in the field.


Partner Country Refine your search based on the country in which Partners reside. Select the country from the drop-down.

Screened Date Refine your search based on the date the Partner was screened. The default value for these drop-downs is blank.

The required formatting for the field is: mm/dd/yyyy - 00:00

Use the Calendar icons ( ) to select a date and ensure proper formatting.

You can further refine the Screened Date by the time of day using the optional Time portion of the input field. Format the time according to the 24-hour clock.

Screened By Refine your search based on the User Name of the person who performed the screening. The drop-down contains all User Names in your company. The default value is blank.

Decision Date Refine your search based on the date the screening decision was made. The default value for these drop-downs is blank.

The required formatting for the field is: mm/dd/yyyy - 00:00

Use the Calendar icons ( ) to select a date and ensure proper formatting.

You can further refine the Decision Date by the time of day using the optional Time portion of the input field. Format the time according to the 24-hour clock.

Decision By Refine your search based on the User Name of the person who made the screening decision. The drop-down contains all User Names in a company. The default value is blank.

Decision Refine your search based on the Decision selected by a User Name when analyzing the screening results for a Partner. The values in the drop-down are: Match, No Match, and Potential

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Fields Description

Match. The default value is blank.

Engine Decision Refine your search based on the decision the engine made when analyzing potential matches for a Partner. The values in the drop-down are: No Match and Potential Match. The default value is blank.

Note: To generate a list of false positive decisions made by the engine, set the value of this field to "Potential Match", and the Decision field to "No Match".

Escalation If your company uses the Escalation functionality, refine your search based on Escalation. The default value is blank.

Rationale If your company uses the Rationale field to document screening decisions, refine your search based on Rationale. The default value is blank.

Recommendation If your company uses the Recommendation field to document screening decisions, refine your search based on Recommendation. The default value is blank.

Click Search to submit your customized search query to the system. The results display on the Partner Search Results page

Partner Search Results

Once you submit a search, the matching Partner records display on the Search Results page. Each row contains the screening results for a Partner. Click the <<Back to Partner Search link to return to the search screen and refine your current search criteria.

You can perform the following actions from the Search Results page:

Screen a Partner: Click the icon to move the record to the Partner Screening page where you can edit the Partner information and screen the record again.

Important: When you modify and manually re-screen a Partner, the system updates the existing database record for the Partner with your modifications.

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View Details: Click the icon to view the Match Details for the Partner record, where you can enter a decision, recommendation, rationale, or escalate the screening record. For details, refer to Using the Search Results - Match Detail Page.

Note: The Internal Compliance Manager role can override a screening decision, rationale, recommendation, and notes for the current screening results record from the Match Details.

If a search returns more than 500 records, the following message displays under the page title:

WARNING: <xxx> records match your search criteria. Only the first 500 are displayed. Refine your search criteria, or request the data in a report.

(Where <xxx> represents the actual number of results returned by the search).

The following table provides information on the different fields comprising the Search Results page.

Field Description


ID The unique identifier for a Partner record.

Type The Partner Type of the Partner record.

Name The potential matches of the input Partner to an entity based on Name. Additional names, which may superficially appear unrelated, may also display. These names are alternate spellings of, or Also Known As (AKA) designations for the restricted entity.

Address The potential matches of the input Address to an entity based on Address. If the system displays multiple Addresses, they are alternative spellings for the entity Address that matched the input Partner.


PENDING – The Partner appears in the Work Queue; the system determined that the Partner matches a restricted entity, but a user must make the final decision.

NO MATCH – The Decision By user determined the Partner does not match a restricted entity.

MATCH – The Decision By user determined the Partner is a restricted entity.

Decision Date

The date the screening decision was made.

Decision By

The User ID of the individual who made the screening decision or SYSTEM for a system-generated match.

Screened The date the Partner was last screened.

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Field Description

Date

Screened By

The User ID of the individual who performed the initial screening.

Options Contains the following two icons:

: Click to move the record to the Partner Screening page.

: Click to view the Match Details for the Partner record.

Search Results Data Manipulation

You can manipulate the display of the records on the Search Results page as follows:

Sort: Click a column heading name to sort the search results by that criteria—in ascending or descending order. The column headings are:

Column Headings

SubOrg

- ID

- Type

- Name

- Address

Decision

- Decision Date

- Decision By

- Screened Date

- Screened By

Group: Use the Group by drop-down menu to organize the results based on any one the following criteria:

Group by Criteria

- SubOrg

- Decision Year

- Decision Hour

- Screened Month

- Screened By

- Partner Type

- Decision Month

- Decision By

- Screened Day

- Decision

- Decision Day

- Screened Year

- Screened Hou

Example: Perform a search for records under your company SubOrg, including child SubOrgs. The system returns all Partner records for the company. Select "SubOrg" as the Group by criteria. The Partner data is grouped according to SubOrg.

The system organizes each grouping of data under a separate section on the page. The section title displays the group name and the number of records in the data group.

Click the section title to expand and collapse the records in the group.

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To remove a data grouping, select the blank space (the first entry) in the Grouped by drop-down.

Using the Search Results - Match Detail Page

When you click the Details icon ( ) for a Partner screening record, the Search Results - Match Detail page displays.

Use this page to determine the relationship between the Partner and the potential matching restricted entity(ies) before making your screening decision.

The Search Results - Match Detail page contains two tabs—Screening Details and Screening History. The page displays the content of one tab and hides the other. You can view the contents of the hidden tab by clicking its name.

For details on the information contained in each tab, refer to:

Using the Screening Details Tab on page 46

Using the Screening History Tab on page 47

To return to the Search Results page, click the <<Back to Search Results link.

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The Screening Details Tab

The Screening Details tab displays by default when you access the Search Results - Match Details page.

Use the Screening Details tab to review the Match Details for the current Partner screening.

For RPL matches, the Screening Details tab contains the Match Details for the current Partner screening.

For Country Screening matches, the Screening Details tab contains a Country Screening warning message that provides details on which rule triggered the Potential Match status.

For Unusual Word matches, the Screening Details tab contains the system-generated note that provides the details of the word(s) that triggered the Potential Match status.

The Screening Details tab also contains the functional elements for you to make a screening decision.

To view the Screening History tab, click the Screening History link.


The following table provides information on the different sections comprising the Screening Details tab:

Section Description

Tabs Contains the two page tabs - Screening Details and Screening History.

Navigation Links

Contains links to navigate within the Search Results:

<<Back to Search Results: Returns to the Search Results page. <<Prev: Displays the Match Details for the previous record in the

Search Results page.

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Section Description

Next>>: Displays the Match Details for the next record in the Search Results page.

Partner Information

Contains the Partner Name and Address information screened by the application and, for RPL matches, the resulting Match Score. To the right of the Match Score, on the same row, is an Export to Excel link to save the Match Details for this screening to an Excel file. For details refer to The Screening Results with Details Excel File on page 26.

Match Score: The probability that the Partner's name is a match to the restricted entity name. A higher score indicates a greater chance of a match. A score of 1.00 indicates a perfect match probability, while 0.00 indicates no match.

The engine considers several factors when calculating the Match Score, including the number of words entered, the number of letter differences between the Partner and the entity, and the weighting of different algorithms used in the match engine.

Decision Section

Contains the necessary fields to make a screening decision.

Note: Screening decisions may not be made by the User role.

Match Details Section

This section contains information explaining why an RPL match occurred and the implications of the match. For additional information, refer to Viewing the RPL Matching Results on page 36.

Country Screening

Displays a warning message when a Partner screening results in a Country Screening Potential Match. The message provides the Country Screening rule that triggered the Potential Match status and provides links to additional information. For details, refer to Viewing the Country Screening Match Details on page 38.

This section only displays for Country Screening Potential Matches.

The Screening History Tab

Note: The system saves the Match Details of past Partner screenings by default. However, the system can be configured not to retain past Match Details by clearing the Audit Partner Screenings check box on the Integration Configuration page. In this configuration, the Match Details for past screenings states "Audit data not available".

To access the Screening History tab from the Search Results - Match Detail page, click the Screening History link.

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Use the Screening History tab to access the following information:

A listing of the Partner's current and previous screening results.

The corresponding Potential Match Details for each screening history record.

A snapshot of the Screening engine's configuration during the Partner screening. This screen is only accessible using the Internal Compliance Manager role. If you attempt you attempt to access this page using another role, the system displays an error message.

To view the Screening Details tab, click the Screening Details link.


The following table provides information on the main components of the Search Results - Screening History tab:

Section Description

Tabs Contains the two page tabs - Screening Results and Screening History.

Navigation Links

Contains links to navigate within the Search Results:

<<Back to Search Results: Returns to the Search Results. <<Prev: Displays the Screening History for previous record in the

Search Results. Next>>: Displays the Screening History for the next record in the

Search Results.

Past Screenings

Lists all previous screening for the Partner. Each screening record displays on a separate row. Each summary displays the following information:

#: A sequence number that identifies each record in the list. Each number is a link that displays the Match Details for that past screening.

Screening Date: The date the screening was performed. Screened By: The User ID of the person who performed the

screening. Decision Date: The date the decision was made. Decision By: The user ID of the person who made the decision. Decision: The screening decision. Configuration Info: (Internal Compliance Manager only) Click the

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Section Description

Details icon ( ) to a view a snapshot of the engine's configuration during the screening. If you attempt you attempt to access this page using another role, the system displays an error message.

Troubleshooting Partner Screening FAQ

The Troubleshooting section addresses frequently asked questions or problems you might experience when using the web interface to screen Partners.

If you follow the steps provided in the section below and your problem persists, contact the TradeSphere Support Group at 1-703-480-7910. Specify that you are using Restricted Party Screening, indicate what you were doing at the time the error occurred, and provide the version of your web browser. Provide your name, company name, and a means of contact.

I receive an error saying my request cannot be processed (Error 500).

Sometimes the application can reject a page request from a web browser. To resolve this problem, refresh the page or click the browser's Back button and repeat the process.

I cannot view the Help files when I click a Restricted Party Screening document name.

You must be logged on to Restricted Party Screening to view the Help files. If your session has timed out, the system prompts you to log on. Return to the Help pages and view the Help file.

I cannot locate a command on the Main Navigation menu.

The commands you see on the Main Navigation menu are determined by your current role. If you do not see a command to which you know you have access, you need to change your current role. You can change your role using the System Menu Bar Role drop-down. If you need to access a command that is not available in one of your currently assigned roles, contact your company's Client Administrator to have the required role added to your User Account.

I made an error on a screening decision! What can I do to correct it?

Your Internal Compliance Manager role can override a screening decision, rationale, recommendation, and notes once a screening decision has been made.

How can I audit the screening of Partners?

Use the Partner Search page with the Restricted Party Screening reports to perform audits on Partner screenings. If you need to know how the engine was configured for a particular Partner screening, the Internal Compliance Manager can access the Historical Configuration page.

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How can I view a list of all current records in a SubOrg?

To retrieve a list of all current records in a SubOrg, select the SubOrg from the System Menu Bar, access the Partner Search page, and click the Search button.

How can I view a list of all records for my company?

To retrieve a list of all records in a company, select the Company SubOrg from the System Menu Bar, access the Partner Search page, and click the Search button. Select "SubOrg" from the Group by drop-down on the Search Results page to group the records by SubOrg.

How can I view a list of "false positive" decisions made by the screening engine?

To generate a list of false positive decisions made by the engine, access the Partner Search page, set the value of the Engine Decision field to "Potential Match", and the Decision field to "No Match".

What web browser versions does Restricted Party Screening support?

Restricted Party Screening supports the following browser:

− Microsoft Internet Explorer™ v6.0, v7.0 and v8.0

Restricted Party Screening was tested on IE v8.0. Older versions of Internet Explorer might display the pages erratically. TradeSphere does not officially support other web browsers, such as Firefox, Opera, and Chrome.

How can I determine the version of the web browser that I am using?

To check your browser version, use the browser's Help facility. In Internet Explorer, from the Help menu, select About Internet Explorer.

When contacting the TradeSphere Support Group, always provide your browser version.

Does Restricted Party Screening support diacritical characters?

Diacritical characters are used in international spellings and are represented by the extended character set of ISO 8859-1. These characters can contain an accent mark, for example, 'é', 'ü', or 'â'. Some of the names of restricted entities on the non-US RPL lists contain diacritical characters. There are two components to screening with diacritical characters. The first is to match a Partner name containing diacriticals. If the RPL entity does not have a diacritical character, then the match is considered less strong, but should occur; the screening engine treats the match as a typographical error. The second aspect to screening diacriticals is the ability for the engine to match an RPL entity with diacriticals. Restricted Party Screening or later supports a character mapping dictionary that allows the screening engine to transform a diacritical character into a regular character to improve the accuracy of a match, for example, to map 'é' to 'e'. Your System Administrator can use the character mapping dictionary to map diacritical characters to regular characters and regular characters to diacritical characters. Restricted Party Screening does not translate words or phrases from one language

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set to another. There are many nuances in translating names and addresses from one language to another that are beyond the present capabilities of the application.

Appendix A - Country Screening Rules Country Screening Rules

Important: This documentation was correct when published; however, sanctions and embargoes change frequently. If Restricted Party Screening suggests a country is or is not covered, the product is correct, and you are encouraged to use the information below to reference the source of the latest information.

During screening, TradeSphere Restricted Party Screening examines the Partner's country against six country-screening Rules:

Enhanced Proliferation Control Initiative (EPCI)

Israeli boycott

US-embargoed Countries

US-proscribed Country List

EU-embargoed Countries

UN-embargoed Countries

Each Rule has different consequences depending on several factors, which are explained in the following sections.

Note: The external URLs in this document are subject to change without notice; the linked content is not maintained by Livingston International. Please report broken links for repair.

Enhanced Proliferation Control Initiative (EPCI) The US Government does not support the proliferation of nuclear weapons, chemical/biological weapons, or the missiles to deliver such weapons, as well as foreign maritime nuclear propulsion projects. This policy is implemented in the end-use and end-user controls referred to as EPCI.

EPCI controls focus on end users (Partners) and end uses. EPCI controls apply to items with either an ECCN or EAR99 classification (i.e., almost everything under the control of BIS). EPCI screening depends upon a client's knowledge of the company's Partners (e.g., depending upon a client's business model, each Partner on a transaction might be subject to EPCI screening) as well as a BIS list of defined countries.

Partner screening is based upon the company's knowledge of their customer's end use, while the Partner's country screening is based upon the country's level of participation

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and cooperation in the various multilateral export control regimes. Restricted Party Screening covers the following EPCI control codes:

NUCLEAR - Nuclear proliferation (countries listed in Group D:2; EAR Supp 740)

CHEM_BIO - Chemical/Biological proliferation (countries listed in Group D:3; EAR Supp 740)

MISSILE -Missile proliferation (countries listed in Group D:4; EAR Supp 740)

Note: The URLs in the RPL Type links are subject to change without notice; the linked content is not maintained by Livingston International. Please report broken links for repair.

Additional Nuclear Controls

The NUCLEAR code contains the additional control of countries not listed in Supplement 3 to EAR Part 744). The countries listed in Supplement 3 to Part 744 are fifteen EU member states, Australia, Canada, Iceland, Japan, New Zealand, Norway, and Turkey.

By default, the remaining 169 countries (depending on definition) are subject to Nuclear EPCI controls. The TradeSphere Data-Compliance Group removed these countries from TradeSphere Restricted Party Screening to reduce the number of country hits. Livingston International recommends that customers regard all destinations as subject to Nuclear EPCI consideration.

The exports or reexports of any item for use in connection with a foreign maritime nuclear propulsion project requires a license to all countries.

Israeli Boycott The US Government does not support unsanctioned foreign boycotts. Specifically, BIS and IRS regulations prohibit US individuals and companies from refusing or requiring other persons to refuse to do business with a boycotted country or a person or company located in the country targeted by the boycott. The regulations also forbid furnishing information about any person's business relationships with any boycotted country. For example, the Arab League boycott of Israel is an unsanctioned foreign boycott and is the focus of the BIS Restrictive Trade Practices or Boycott regulations.

Semi-annually, the Treasury Department publishes a list of countries that may require participation in, or cooperation with, an international boycott. Although it is important to remember that a request can come from any country, the following list was furnished by the Treasury on July 7, 2006:

Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, and Yemen

Within TradeSphere Restricted Party Screening, boycott controls focus on the end user (Partner) and country. Boycott controls apply to the transaction, not the items. Boycott screening depends upon a customer's knowledge of all communications relating to a specific order/transaction. The most common methods of communicating instructions on compliance with a boycott are: boycott questionnaires, RFQs, POs, shipping instructions, and letters of credit. Prohibited conduct (complying with a boycott) is extremely hard to define and is usually left to the discretion of a trade expert.

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US-Embargoed Countries To implement US government policies, the BIS (Bureau of Industry and Security in the Department of Commerce), OFAC (Office of Foreign Assets Control in the Treasury Department), and ODTC (Office of Defense Trade Controls in the Department of State) impose comprehensive embargoes and supplemental controls for items and activities subject to their jurisdiction.

BIS imposes comprehensive controls on commodities and technical data over which they exercise jurisdiction.

OFAC imposes comprehensive controls over the transfer of assets to or from designated people, organizations, or countries.

ODTC controls weapons and military equipment.

BIS and OFAC imposed comprehensive embargoes on Cuba, Iran, Syria, and Sudan; limited embargoes are imposed on Rwanda and Antarctica. For the limited embargoed countries, the application over-controls and marks the entire country as embargoed. See the individual country details listed in the table below.

Certain Ship to Partners are not subject to a country's embargo, while others are. Embassies are the best example of a Ship to Partner located in one country while being subject to the controls placed on another country.

Any commodities may be exported to an embargoed country with the proper license or license exception.

The following is a list of countries that Livingston International considers embargoed along with the reason for the embargo:

Country Description of the Controls

Antarctica Exports to Antarctica are exports to the country that exercises jurisdiction over the facility. The country control has been set to embargo to give the exporter an opportunity to determine the actual "country" of destination.

Antarctica consists of the territory south of 60 degrees south latitude. This area includes claims by Argentina, Australia, Chile, France, New Zealand, Norway, and the United Kingdom, the legal status of which remains in suspense under the terms of the Antarctic Treaty of 1959. The United States recognizes no claims to Antarctica.

Cuba OFAC license may be required. All items on CCL and most EAR99 items require a license from BIS (Bureau of Industry and Security).

Iran OFAC license required. BIS does not require a license if OFAC authorizes the export or re-export.

Rwanda BIS maintains a general policy of denial on a variety of commodities that to most other countries would be NO LICENSE REQUIRED.

Sudan OFAC license required. An OFAC license does not relieve the Exporter of the responsibility of obtaining a license from BIS, if required. Because of the

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OFAC license requirement, the country control has been set to EMBARGO to give the Exporter an opportunity to review all transactions with Sudan.

Syria Prohibition on the export of all items on the Commerce Control List (in 15 CFR Part 774) (CCL) and (2) a prohibition on the export of products of the United States, other than food and medicine.

US-Proscribed Country List The United States denies licenses, other approvals, exports and imports of defense articles and defense services, destined for or originating in certain countries.

For more information, refer to Directorate of Defense Trade Control's Embargo Reference Chart and http://www.pmddtc.state.gov/docs/ITAR/22cfr126_Part_126.pdf.

Note: The Directorate of Defense Trade Control website contain links to detailed information in the applicable Federal Regulation(s).

This policy applies to:

Country Date Federal Regulation

Comments

Afghanistan 06/27/1996 05/8/2001 07/2/2002

61 FR 33313 66 FR 23310 67 FR 44352

Amendment to ITAR 126.1 Denial Policy to territory of Afghanistan under Taliban control and all of Afghanistan Denial Policy to Afghanistan except for Government of Afghanistan and ISAF

Burma 06/16/1993

07/22/1993

58 FR 33293

58 FR 39280

Department of State Suspension Notice

Amendment to ITAR 126.1

Belarus 07/22/1993 58 FR 39280 Amendment to ITAR 126.1

China (PR) 06/7/1989

07/22/1993

54 FR 24539

58 FR 39280



Côte d'Ivoire 12/14/2004 69 FR 74560 Department of State Suspension Notice

Cuba 12/6/1984 49 FR 47682 Amendment to ITAR 126.1

http://www.pmddtc.state.gov/country.htm

http://www.pmddtc.state.gov/country.htm

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Comments

Cyprus 12/18/1992 57 FR 60265 Department of State Denial Notice; does not affect export for the UN forces in Cyprus (UNFICYP) or for civilian end- users

Democratic Republic of the Congo

04/29/1993 07/22/1993 02/17/2004 08/30/2005

58 FR 26024 58 FR 39280 69 FR 7349 70 FR 50966

Department of State Suspension Notice Amendment to ITAR 126.1 Modified Denial policy to DROC Further modification of Denial Policy to the DROC.

Eritrea 03/6/2006 71 FR 11281 Department of State Suspension Notice

Haiti 10/9/1991

04/4/1994

10/4/2006

56 FR 50968

59 FR 15624

71 FR 58496



Partial Lifting of Arms Embargo

Iran 01/23/1984

10/29/1991

49 FR 2836

56 FR 55630

Department of State Notice designating Iran as a terrorist country


Iraq 08/3/1990 09/13/199

10/29/1991 11/21/2003 04/9/2004

55 FR 31808 55 FR 37793 56 FR 55630 68 FR 65633 69 FR 18810

Department of State Revocation Notice Department of State Notice designating Iraq as a terrorist country Amendment to ITAR 126.1 Denial policy to Iraq except for Iraqi military or police force required by Coalition Provisional Authority. Denial policy to Iraq except for nonlethal military equipment, lethal military equipment for use by reconstituted (or interim) Iraqi military or police force, and small arms for use for private security purposes.

Lebanon 12/15/2006 71 FR 75609 Department of State Suspension Notice

Liberia 12/18/1992

07/22/1993

57 FR 60265

58 FR 39280



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Comments

09/5/2001 66 FR 46491 Continued denial policy

Libya 10/29/1991 56 FR 55630 Amendment to ITAR 126.1

North Korea 12/6/1984 49 FR 47682 Amendment to ITAR 126.1

Rwanda 06/2/1994

08/17/1994 07/30/2003

59 FR 28583

59 FR 42158 68 FR 44613

Department of State Suspension Notice; Licenses and approvals suspended until further notice; current applications to be denied


Denial policy to Rwanda except for Government of Rwanda

Somalia 12/16/1992

07/22/1993

57 FR 59851

58 FR 39280



Sudan 11/3/1992

10/8/1993

04/4/1994

58 FR 49741

58 FR 52523

59 FR 15624


Department of State Notice designating Sudan as a country supporting terrorism


Syria 10/29/1991 56 FR 55630 Amendment to ITAR 126.1

Venezuela 08/17/2006 71 FR 47554 Department of State Notice on Revocation and Denial of Defense Export Licenses

Vietnam 12/6/1984 49 FR 47682 Amendment to ITAR 126.1

Yemen 12/16/1992 57 FR 59852 Department of State Notice; presumption of denial for lethal articles or items supporting such articles or services

Zimbabwe 04/17/2002

07/23/2002

67 FR 18978

67 FR 48242


Use of Exemption at 123.7

EU-Arms Embargo and Other Sanctions The European Union maintains specific restrictions against a number of countries. These change on a relatively frequent basis. The current embargoed countries are:

Belerus, Bosnia and Herzegovina, China, Croatia, Democratic Republic of the Congo, Iraq, Ivory Coast (Cote d'Ivoire), Lebanon, Liberia, Macedonia, Moldavia, Myanmar, Sierra Leone, Somalia, Sudan, Syria, Uzbekistan, Yugoslavia, Serbia and Montenegro, and Zimbabwe.

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Details can be found on the Common Foreign & Security Policy (CFSP) website.

Legal Basis for Imposing Sanctions/Embargoes

Note: For information on EU sanctions, refer to refer to the External Relations & European Neighborhood Policy website.

Many of the measures are adopted to implement a United Nations (UN) Security Council Resolution, while other sanctions have been "autonomous" in character. The legal nature of the measures adopted depends on the area covered: measures falling under Community jurisdiction are taken by an EC regulation under the Treaty Establishing the European Community (TEC); while measures falling under member state competence (CFSP) are adopted by a Common Position under the Treaty on European Union (TEU). The latter must then be implemented by member state domestic legal provisions.

Arms embargoes and restrictions on exports generally fall under the member states' exclusive jurisdiction, according to Article 296, of the Treaty Establishing the European Community (TEC). This means that EU institutions lack formal powers to influence the member states' policies in this field. From 1973 to 1992, the member states used the informal foreign policy coordination process, European Political Cooperation, to develop a common approach and generally agreed that arms embargoes mandated by the United Nations should be respected. Occasionally, member states, under the umbrella of the Council of Ministers, issued declarations to impose embargoes.

With the entry into force of the Treaty on European Union (TEU) in November 1993 and the introduction of the Common Foreign and Security Policy (CFSP), member states now rely on Article 12 and Article 15 (TEU) to introduce common actions. Arms embargoes are adopted by a Common Position specifying the kind of material covered by the embargo and the conditions for its implementation.

General embargoes, whether covering economic relations between the Union and the country concerned, in their entirety or only in part, are often adopted to implement a UN Security Council resolution, which is cited directly in the text of the Common Position. The Common Positions are coupled with an EC Regulation, dealing with an area of Community jurisdiction (Article 301, TEC).

Measures of a more specific character-investment prohibition, freeze of assets, restrictions on persons' movements, etc.-have been adopted in certain cases. Such actions can encompass prohibiting the export of equipment that might be used for internal repression or terrorism; freezing of funds held abroad; banning credit facilities and new investments; and banning flights. Given the nature of the measures, in many cases both a Common Position and an EC Regulation are needed. The Common Position has the usual Article 12 or Article 15 legal basis. The legal basis of the EC Regulations has included Article 60 (TEC) relating to the movement of capital as well as Article 301.

Existing agreements between the EU and specific countries or groups of countries may limit the Union's autonomy to adopt economic sanctions toward them. For this reason more recent agreements contain clauses allowing for suspension or termination of such agreements in particularly serious cases.


Belarus Travel and financial restrictions.

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Bosnia and Herzegovina Travel and financial restrictions.

China Arms embargo. The ban applies to:

Lethal weapons such as machine guns, large caliber weapons, bombs, torpedoes, rockets, and missiles.

Specially designed components of the above and ammunition.

Military aircraft and helicopters, vessels of war, armored fighting vehicles, and other such weapons platforms.

Any equipment which might be used for internal repression.

The Democratic Republic of the Congo

Arms embargo, travel and financial restrictions.

Cote D'Ivoire Arms embargo, travel and financial restrictions.

Croatia Financial restrictions.

Iraq Arms embargo (with exemptions). Assets Freeze (with exemptions).

Lebanon Restrictions on admission of certain persons. Freezing of funds and economic resources of certain

persons.

Liberia Arms embargo with exemptions. Ban on the import of rough diamonds. Travel restrictions.

Macedonia, Former Republic of Yugoslavia

Travel restrictions.

Moldova Travel restrictions.

Myanmar (Burma) Arms embargo. Freeze of funds. Visa ban.

Sierra Leone Arms embargo. Travel restrictions.

Somalia Arms embargo.

Sudan Arms embargo. Asset freeze. Travel restrictions.

Syria Travel restrictions.

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Asset freeze.

Uzbekistan Arms embargo. Travel restrictions.

Yugoslavia, Serbia and Montenegro

Asset freeze.

Zimbabwe Arms embargo. Asset freeze. Travel restrictions.

As relatively informal measures, cultural sanctions reduce cultural and sports contacts or scientific cooperation, for example. Flight bans between the EU and non-member states illustrate the use of restrictions applied to transport.

The EU's economic weight fortifies its application of commercial and economic sanctions. Whether applied selectively or comprehensively, these restrictions on exports and/or imports (trade embargoes) constitute the most important instrument of crisis management currently available. Regularly, however, economic sanctions are complemented by humanitarian exemptions applicable to exports of food and medicinal supplies in order to prevent the suffering of the civilian population in the target country.

Similarly, the EU has enacted a Community Certification scheme [Council Regulation (EC) No 2368/2002, amended by Council Regulation (EC) No 254/2003 and Commission Regulation (EC) No 257/2003] for the international trade in rough diamonds. The purpose of the certification scheme is to prevent "conflict" or "blood" diamonds from fueling armed conflicts, such as those in Angola, Sierra Leone, and the DR Congo, thereby contributing to the EU's policy on conflict prevention. (See Conflict Prevention & Civilian Crisis Management for further details.) An effective ban will deprive rebel movements of significant finances and will therefore be an important contribution to peace and stability. The scheme also aims to prevent conflict diamonds from discrediting the legitimate market for rough diamonds, which makes an important economic contribution, not least to certain developing countries in Africa. Less than 4% of global diamond production is regarded as "conflict diamonds," while a number of developing countries that are major producers and processors of diamonds depend heavily on the legitimate diamond industry for their economic and social development.

In addition to economic sanctions, financial sanctions can be imposed, including bans on the movement of capital and on payments. Financial measures can also be targeted to punish specific individuals by freezing their personal funds abroad.

These sanctions are important because their implementation falls under Community competence, which facilitates their uniform and effective implementation and enhances the Commission's role in the process. After member states decide to adopt economic sanctions [within the Common Foreign and Security Policy (CFSP) framework], the Commission prepares and implements the sanctions. The European Court of Justice has jurisdiction to deal with economic sanctions when they are implemented by Council regulations.

Arms embargoes, as a non-military instrument of crisis management, are used to stop the flow of arms to conflict areas. Motivation for arms embargoes is often more humanitarian

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than punitive, and often they are associated with explicitly coercive measures, such as economic sanctions.

The latest sanction and embargo information can be found on the UK Foreign and Commonwealth Office (FCO) web site. The FCO maintains the latest country regulations for controls in place by the UK, EU, and UN and provides the relevant citation information.

UN-Arms Embargo and other Sanctions The United Nations periodically issues United Nation Security Resolutions (UNSCRs) imposing various restrictions. Currently, the UN has the following active sanctions committees regarding the following countries:

The Democratic Republic of the Congo, Cote D'Ivoire, Liberia, Rwanda, Sierra Leone, Somalia and Sudan.


The Democratic Republic of the Congo

Arms embargo, travel and financial restrictions.

Cote D'Ivoire Arms embargo, travel and financial restrictions.

Liberia Arms embargo and ban on provision to Liberia of related technical assistance training.

Ban on the import of rough diamonds from Liberia. Travel ban on senior members of the Government of Liberia and

its armed forces and their spouses and any other individuals providing financial and military support to armed rebels groups in countries neighboring Liberia as designated by the UN Sanctions Committee.

Rwanda Arms embargo on non-governmental forces.

Sierra Leone Arms embargo other than to the Government of Sierra Leone through named entry points. Exceptions for UN and Military Observer Group of the Economic Community of West African States (ECOMOG) for their sole use in Sierra Leone.

Travel restrictions on named members of the military junta and adult members of their families.

Somalia Arms embargo.

Sudan Arms embargo, travel and financial restrictions.

The latest UN sanctions can be found on the Security Council Sanctions Committees web site.

Another source can be found on the UK Foreign and Commonwealth Office web site. The FCO maintains the latest country regulations for controls in place by the UK, EU, and UN and provides the relevant citation information.

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Index A Accessing the Application.........................................11 Actions......................................................................31 Additional Nuclear Controls ......................................52 Appendix A - Country Screening Rules.....................51 Application Architecture ............................................29 Architectural Overview - Hosted Implementation......29 Audience - User Role .................................................1

C Changing Your Session Settings ..............................20 Controlling System Access ...................................7, 15 Country Screening Rules..........................................51 Customizing Partner Searches .................................40

D Data Archiving ..........................................................30 Documentation Set .....................................................3

E Enhanced Proliferation Control Initiative (EPCI) .......51 EU-Arms Embargo and Other Sanctions..................57 Exporting a Partner's Screening Results to Excel.....25

F Functionality ...............................................................4

I Introduction.................................................................1 Introduction to Restricted Party Screening .................1 Israeli Boycott ...........................................................52

L Legal Basis for Imposing Sanctions/Embargoes ......57 LiveTradeSync Automates Restricted Party List

Updates..................................................................6 Locating Information in Restricted Party Screening..21 Logging Off From Restricted Party Screening ..........24 Logging On to Restricted Party Screening ...............13

M Main Navigation Menu..............................................15 Managing Custom Configurations ..............................9 Maximizing Your Work Space ...................................16

N No Potential Match ...................................................10

O Overview ....................................................................1

P Partner Screening .................................................... 31 Partner Screening FAQ ............................................ 49 Partner Search......................................................... 40 Partner Search Results ............................................ 42 Partner-Screening Events .......................................... 6 Performing Partner Searches................................... 40 Potential Match Types.............................................. 10 Product Nomenclature ............................................... 2

R Role Home Page...................................................... 14 Role Security.............................................................. 7

S Screening Capabilities ............................................... 5 Search Results Data Manipulation ........................... 44 Selecting Dates with the Calendar Icon ................... 23 Summary - User Role................................................. 1 System Maintenance................................................ 30 System Menu Bar..................................................... 14

T The Content Pane .................................................... 15 The Country Screening Potential Match...... 10, 11, 39 The Restricted Party Screening Work Space ........... 14 The RPL Potential Match ......................................... 10 The Screening Details Tab ....................................... 46 The Screening History Tab................................. 46, 47 The Screening Results Excel File ............................ 25 The Screening Results with Details Excel File .. 25, 26,

36, 47 The Unusual Word Potential Match.............. 10, 11, 39 Troubleshooting ....................................................... 49

U UN-Arms Embargo and other Sanctions .................. 60 Updating and Re-Screening a Partner ..................... 33 Updating the General Section ............................ 13, 18 Updating the Personal Information Section.............. 19 Updating the SubOrg Data Section .......................... 20 Updating Your User Profile....................................... 17 US-Embargoed Countries ........................................ 53 User Guide Overview ................................................. 1 Using a Customer-Specific ID to Screen a Partner .. 35 Using Field Filters .............................................. 22, 40 Using the Search Results - Match Detail Page ........ 45 Using the System-Generated ID to Screen a Partner

............................................................................. 33 US-Proscribed Country List...................................... 54

V Versioning .................................................................. 2 Viewing Screening Results....................................... 35 Viewing the Country Screening Match Details .. 11, 36,

47

62


Viewing the RPL Match Details............... 11, 36, 37, 47 Viewing the Unusual Word Match Note .............. 11, 39

W Web-Interface Basics ...............................................11 Welcome E-mail and Initial Password ......................12 Why Use Restricted Party Screening .........................4

tradesphere restricted party screening

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