Export Compliance Just Got More Complicated (Here are Links to Make it Easier)

Normally, the consolidated screening list is found on export.gov; but now that entire website simply returns the message “Due to the lapse in government funding Trade.gov and Export.gov and all associated online activities will be unavailable until further notice.”  For exporters who rely on the consolidated screening list as a compliance tool, this is a significant problem.

Interestingly enough, export enforcement – the ongoing conduct of criminal investigations, and prosecutions, and coordination with other law enforcement and intelligence agencies – has been deemed to be an essential service for the Commerce Department so even though compliance resources are missing, export enforcement will still be available to punish anyone who makes a mistake because of the missing resources.

Due to the lapse in government funding
Trade.gov and Export.gov
and all associated online activities
will be unavailable until further notice

So how do we ensure continued compliance for our exports?  If you’ve been to one of ASA’s export workshops, then you know that the consolidated list is supported by separate iterations of the lists that are consolidated. Some of these lists are still available for review.  Here are some that are particularly useful for civil aircraft parts transactions:

• Sanctions Programs and Country Information List: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
• Specially Designated Nationals And Blocked Persons List: http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx
• Denied Persons List: http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/denied-persons-list (note: last updated December 31, 2018)
• Denied Entities List (unofficial): http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list
• Denied Entities List (official, CFR): https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=9ae4a21068f2bd41d4a5aee843b63ef1&ty=HTML&h=L&n=15y2.1.3.4.28&r=PART#ap15.2.744_122.4
• Unverified List: https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=9ae4a21068f2bd41d4a5aee843b63ef1&ty=HTML&h=L&n=15y2.1.3.4.28&r=PART#ap15.2.744_122.6