System Description

Compliance Screening

Legal regulations and available restricted party lists

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© 2021
Date: July 6, 2021
Contents

1 Change history 1

2 Against which restricted party lists should an EU-based company screen? 2

2.1 EU regulations against which to screen 2
2.2 US restricted party lists against which to screen 2

3 Which lists does AEB currently offer in the Compliance solution? 3

3.1 Lists offered in the AEB data service 4
3.1.1 EU lists 4
3.1.2 UK lists 7
3.1.3 US lists 8
3.1.4 Japan lists 15
3.1.5 Switzerland lists 15
3.1.6 Singapore lists 16
3.1.7 Australia lists 16
3.1.8 Further lists 17
3.2 Lists by Reguvis (former Bundesanzeiger Verlag; subject to license fees) 18
3.3 Dow Jones content (subject to license fees) 19
3.4 Can AEB provide the German BMWi Frühwarnhinweise via data service? 20
1 Change history
Date Modification Chapter
(please cross-
reference)

18.02.2020 Footnotes added to Entity List and List of Nonproliferation 3.1.3 (} page 8)
Sanctions

18.02.2020 New US list SAM (System for Award Management 3.1.3 (} page 8)
Exclusions)

18.02.2020 Dow Jones: "SOR" sanctions package renamed "SCO” 3.3 (} page 19)

08.05.2020 Ministry of the Dutch list corrected to Ministerie van 3.1.1 (} page 4)
Buitenlandse Zaken

19.10.2020 Current pricing model implemented Various

04.02.2021 Description of CFSP List updated 3.1.1 (} page 4)

04.02.2021 Section “UK lists” extended and existing BOE and UKUASL 3.1.2 (} page 7)
lists moved here, new UKSL list added

04.02.2021 New MEUL list added; SDN list extended by further 3.1.3 (} page 8)
sanctions programs; OFAC-CSL list extended by a new
restricted party list

04.02.2021 Descriptions of the BANZEU, BANZUS, and BANZDIV lists 3.2 (} page 18)
updated

08.02.2021 Descriptions of UKUASL and UKSL lists improved 3.1.2 (} page 7)

14.05.2021 OFAC-CSL list extended by new restricted party list 3.1.3 (} page 8)

06.07.2021 New DFAT list added 3.1.7 (} page 16)

1
2 Against which restricted party lists should an EU-
based company screen?
2.1 EU regulations against which to screen
Generally, companies with headquarters in the EU only need to consider those restricted party lists/denied-
party lists that are mentioned in the EU embargo regulations or in national law.
There are two types of embargo regulations against whose annexes a company’s business partners must be
screened. On the one hand, these are embargoes on individuals as defined in the “anti-terrorism regulations”,
EU Regulations Nos. 881/2002 (ISIL (Da‘esh) and Al Qaida), 2580/2001 (terror suspects), and 753/2011
(Afghanistan) including all amendments to these regulations.
On the other hand, there are EU embargo regulations for countries which include lists of names, e.g. for
countries such as Iran, Iraq, Congo (Democratic Republic), North Korea, Sudan, etc.
On the website of the responsible authorities of the EU member states, you can find the anti-terrorism
regulations as well as an up-to-date list of all country-specific embargo regulations, some of which include
lists of names in their annexes: http://www.bafa.de/DE/Aussenwirtschaft/Ausfuhrkontrolle/Embargos/
embargos_node.html

2.2 US restricted party lists against which to screen

The United States asserts worldwide authority for its export control laws. Companies with headquarters in the
EU are recommended to also screen their business partners against US sanctions lists, called “Black Lists”.
Companies whose activities fall under US jurisdiction must ensure that they comply with the provisions of this
jurisdiction. In the US, a multitude of Black Lists with various backgrounds and legal consequences exist. Only
some of them claim global applicability.

2
3 Which lists does AEB currently offer in the
Compliance solution?
AEB offers you an automatic update service as an integral part of your AEB Compliance solution. This update
is a fully automated background process without the need for any user interaction. AEB updates the current
versions of the restricted party lists daily and maintain them for you on a central server in the AEB data
center.
Currently, the extensive international list content is available to you as detailed in the following. This list
content is extended continuously. Additionally, AEB is working with some partner companies that also
provide lists for various countries.
Which lists your application checks depends on your license agreement. The scope of the update service is
thus tailored to your company’s individual needs.

3
3.1 Lists offered in the AEB data service
3.1.1 EU lists
European External Action Service (EEAS)

List Description Relevance Price Material

category number

CFSP Consolidated list of all persons, groups, and entities subject to EU financial For companies with Included in −
Consolidated sanctions. The CFSP list is the official EU database. It includes the financial headquarters in the EU, license
Financial sanctions from the anti-terror regulations, the country-specific embargo screening against the
Sanctions List regulations, and other sanctioning regulations such as those against cybercrime CFSP list is mandatory.
or serious human rights violations.

Council of the European Union

List Description Relevance Price Material

category number

EURUDU This list contains Russian organizations concerned by the sanctions laid down in Screening against this list Included in –
EU – Russia light of Russia’s actions to undermine Ukraine's stability. The list contains the is recommended for all license
embargo: entries of annex IV of Council Regulation (EU) No. 833/2014 of July 31, 2014, and companies with
Restrictions amended by Council Regulation (EU) No. 960/2014 of September 8, 2014. headquarters in the
for dual-use EU and dual-use business
goods in Russia.
intended for
listed
organizations

4
 List Description Relevance Price Material
category number

EURUKM It lists Russian entities that are more than 50% state-owned and are subject to Screening against this list Included in –
EU – Russia the sanctions laid down with respect to Russia's actions contributing to Ukraine's is recommended for all license
embargo: destabilization. The list consolidates the entries of annex III of Council Regulation companies with
Restrictions (EU) No. 833/2014 of July 31, 2014, and of annexes II and III of the related headquarters in the EU
on access to amending regulation 960/2014 of September 8, 2014. and in business with
the capital securities and money-
market market instruments in
Russia.

France – Ministère de l'Économie et des Finances

List Description Relevance Price Material

category number

FRNL The French sanctions list contains all persons and organizations subject to EU Recommended for A D601009
French financial sanctions or UN Security Council sanctions, as well as all persons and companies governed by
Sanctions List organizations deemed by the French authorities to be linked to terrorist acts. French law.

5
Netherlands – Ministerie van Buitenlandse Zaken

List Description Relevance Price Material

category number

NLNST The Dutch restricted party list (Nationale sanctielijst terrorisme) complements Recommended for A D601010
Nationale the EU financial sanctions and lists persons and organizations involved in companies governed by
sanctielijst terrorist activities. Under Sanctions Regulation No. DJZ / BR / 1222-07 of Dutch law.
terrorisme December 18, 2007 (“Sanctieregeling terrorisme 2007-II”), all assets of the listed
persons and organizations are frozen. This means that they can no longer access
their money or use their bank accounts and credit cards. This makes it more
difficult for these people to commit terrorist acts or to participate in them
(financially).

Belgium – Federal Public Service FINANCIAL SERVICES (FPS)

List Description Relevance Price Material

category number

BENS The Belgian restricted party list complements the EU financial sanctions and lists Recommended for A D601011
Belgian persons and organizations associated with terrorist activities. All funds and companies governed by
National economic assets of the listed persons and entities are to be frozen without any Belgian law.
Sanctions List delay and the direct or indirect provision of funds and economic assets to these
persons and entities is prohibited.

6
3.1.2 UK lists
HM Treasury – The UK government's economic and finance ministry

List Description Relevance Price Material

category number

BOE Database of all listed persons, groups, and entities subject to financial sanctions For companies with A D601007
Consolidated by the UN and the UK. headquarters in the UK,
List of screening against the
Financial BOE list is mandatory.
Sanctions
Targets in the
UK

UKUASL The List of entities subject to capital market restrictions, provided by HM For companies with A D601008
List of entities Treasury, lists Russian entities that are more than 50 % state-owned and are headquarters in the UK,
subject to subject to the sanctions laid down with respect to Russia's actions contributing screening against the
capital to Ukraine's destabilization. These sanctioned organizations are subject to other UKUASL list is
market financial and investment restrictions and are therefore not included in the OFSI recommended.
restrictions Consolidated List of Financial Sanctions Targets in the UK (BOE list). The list
(former consolidates the entries in Schedule 2 of the Russia (Sanctions – EU Exit)
Ukraine Regulations 2019.
Sovereignty
List)

7
Foreign, Commonwealth & Development Office

List Description Relevance Price Material

category number

UKSL With the UK Sanctions List, the British government provides a list of persons, For companies with A D601022
UK Sanctions entities, or means of transport that are subject to both financial sanctions and headquarters in the UK,
List restrictions on entry, trade, and other restrictions depending on the respective screening against the
national sanctions regimes of the United Kingdom. This is based on the UKSL list is mandatory.
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) and UN Security
Council resolutions. Since the end of the Brexit transition period, the UK is no
longer bound to the EU sanctions.
Although the UK Sanctions List is not part of the OFSI Consolidated List of
Financial Sanctions Targets in the UK (BOE List), at least the individual persons,
entities, or means of transport subject to financial sanctions will also be included
in the BOE List.

3.1.3 US lists
Department of Commerce – Bureau of Industry and Security (BIS)

List Description Relevance Price Material

category number

DPL The Denied Persons List contains the names of those who have Screening against this list is Included in –
Denied violated US export regulations and against whom the Bureau of recommended for all companies who license
Persons List Industry and Security has therefore issued a denial order. The listed trade in US goods directly or
persons have been denied all exporting privileges, meaning that no indirectly, or are US persons and
US goods can be provided to or purchased from them. Businesses therefore subject to US law.
that violate such a denial order are in violation of US export
regulations and risk being listed on the DPL themselves.

8
 List Description Relevance Price Material
category number

EL The Entity List lists persons and entities implicated by American Screening against this list is Included in –
Entity List* authorities as posing a significant threat in the proliferation of recommended for all companies who license
weapons of mass destruction or missile technology. trade in US goods directly or
indirectly, or are US persons and
therefore subject to US law.

UL The Unverified List has the character of an early-warning list. It Screening against this list is Included in –
Unverified contains the names of all persons for which US authorities cannot recommended for all companies who license
List verify sufficiently and have therefore been flagged as potentially trade in US goods directly or
unauthorized to purchase goods of US origin. indirectly, or are US persons and
therefore subject to US law.

MEUL The Military End User List contains companies that are classified by Screening against this list is A D601023
Military End the US government as military end users. According to the findings recommended for all companies who
User List* of the US authorities, the listed companies pose a significant risk of a trade in US goods directly or
military end-use of the goods from Supplement No. 2 to Part 744 indirectly, or are US persons and
EAR. therefore subject to US law.

* Like the Military End User List (MEUL) and the Nonproliferation Sanctions (NPS), the Entity List (EL) is generated from the US Consolidated Screening List (USCSL).
Occasionally, some time may elapse before listings published in the Federal Register are included in the USCSL and therefore in the EL, MEUL, or NPS in Compliance
Screening Please note the instructions of USCSL on the following website: https://www.export.gov/article?id=Consolidated-Screening-List.

9
Department of the Treasury – Office of Foreign Assets Controls (OFAC)

List Description Relevance Price Material

category number

SDN The SDN list contains the names of all persons, groups, and entities worldwide Screening against this list Included in –
Specially implicated by American authorities as involved in terrorist activities threatening is recommended for all license
Designated US security. companies who trade in
Nationals List US goods directly or
Active SDN sanctions programs*:
indirectly, or are US
l Balkans-Related Sanctions persons and therefore
l Belarus Sanctions subject to US law.
l Blocking Property of Certain Persons Associated with the International
Criminal Court Sanctions
l Burundi Sanctions
l Central African Republic Sanctions
l Countering America's Adversaries Through Sanctions Act of 2017
(CAATSA)
l Counter Narcotics Trafficking Sanctions
l Counter Terrorism Sanctions
l Cuba Sanctions
l Cyber-related Sanctions
l Democratic Republic of the Congo-Related Sanctions
l Foreign Interference in a United States Election Sanctions
l Global Magnitsky Sanctions
l Hong Kong-Related Sanctions
l Iran Sanctions
l Iraq-Related Sanctions
l Lebanon-Related Sanctions

10
List Description Relevance Price Material
category number

l Libya Sanctions
l Magnitsky Sanctions
l Mali-Related Sanctions
l Nicaragua-Related Sanctions
l Non-Proliferation Sanctions
l North Korea Sanctions
l Rough Diamond Trade Controls
l Somalia Sanctions
l Sudan and Dafur Sanctions
l South Sudan-Related Sanctions
l Syria Sanctions
l Syria-Related Sanctions
l Transnational Criminal Organizations
l Ukraine-/Russia-Related Sanctions
l Venezuela-Related Sanctions
l Yemen-Related Sanctions
l Zimbabwe Sanctions

OFAC-CSL With the Consolidated Sanctions List, the OFAC provides a consolidated list of all As this is a consolidation Included in –
Consolidated persons and entities of its non-SDN sanctions programs. The Consolidated of various individual lists, license
Sanctions List Sanctions List is not part of the Specially Designated Nationals and Blocked please refer to the
(OFAC) Persons List (SDN) of the OFAC. Nevertheless, it is possible that individual individual lists to assess
entries are also included in the SDN list. the relevance.
The OPAF Consolidated Sanctions List includes the following sanctions lists, for
example:

11
 List Description Relevance Price Material
category number

l Foreign Sanctions Evaders (FSE) List

l Sectoral Sanctions Identification (SSI) List
l Palestinian Legislative Council (NS-PLC) List
l Non-SDN Iranian Sanctions Act (NS-ISA) List
l List of Foreign Financial Institutions Subject to Correspondent Account or
Payable-Through Account Sanctions (CAPTA List)
l Non-SDN Menu-Based Sanctions (NS-MBS) List
l Non-SDN Communist Chinese Military Companies (NS-CCMS) List

* For an overview of all sanctions programs and their impact, refer to the OFAC website: https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-
nationals-list-sdn-list/pro-gram-tag-definitions-for-ofac-sanctions-lists
Department of State – Directorate of Defence Trade Controls (DDTC)

List Description Relevance Price Material

category number

LADP The persons and entities on this list have been convicted by the US Screening against the list A D601013
List of Administration of violations of the Arms Export Control Act (AECA). Listed is recommended for all
Administrativ persons are excluded from trade in US defense equipment including technical companies trading in US
ely data and services. defense articles.
Debarred
Parties

LSDP The persons and entities on this list have been convicted by the US Screening against the list A D601014
List of Administration of violations of the Arms Export Control Act (AECA). Listed is recommended for all
Statutorily persons are excluded from trade in US defense equipment including technical companies trading in US
Debarred data and services. defense articles.
Parties

12
Department of the Treasury – Financial Crimes Enforcement Network

List Description Relevance Price Material

category number

FINCEN Special measures for jurisdictions, financial institutions, or international Screening against this list A D601012
Money transactions of money laundering concern. List for identifying customers who are is relevant for companies
Laundering using correspondent accounts, including obtaining information comparable to that are subject to US law.
Concerns List information obtained on domestic customers and prohibiting or imposing
conditions on the opening or maintaining of correspondent or payable-through
accounts for a foreign banking institution in the US. FINCEN is provided with a
range of options that can be adapted to target most effectively specific money-
laundering and terrorist-financing concerns.

Department of State – Bureau of International Security and Nonproliferation

List Description Relevance Price Material

category number

NPS The United States imposes sanctions under various legal authorities against Screening against this list A D601016
List of foreign individuals, private entities, and governments that engage in proliferation is relevant for companies
Nonproliferati activities. that are subject to US law.
on
Sanctions*

* Like the Entity List (EL) and the Military End User List (MEUL), the Nonproliferation Sanctions (NPS) is generated from the US Consolidated Screening List (USCSL).
Occasionally, some time may elapse before listings published in the Federal Register are included in the USCSL and therefore in the EL, MEUL, or NPS in Compliance
Screening Please note the instructions of USCSL on the following website: https://www.export.gov/article?id=Consolidated-Screening-List.

13
Department of State – Bureau of Counterterrorism and Countering Violent Extremism

List Description Relevance Price Material

category number

TEL The Terrorist Exclusion List is based on the USA Patriot Act of 2001. It contains Screening against this list A D601015
Terrorist specific terrorist organizations and serves as a basis for decisions for granting is at the company’s
Exclusion List entry permissions. A person associated with an organization on the Terrorist discretion.
Exclusion List can be refused entry into the United States of America.

General Services Administration (SAM)

List Description Relevance Price Material

category number

SAM The System for Award Management (SAM) Exclusions contains a list of parties Screening against this list B D601005
System for (individuals, companies, entities, or vessels) that are not permitted to receive is essential for companies
Award government contracts or certain types of financial and non-financial assistance participating in the US
Management and benefits from the US government. A listed individual or legal entity may be government's system of
Exclusions excluded by several US authorities at the same time. awarding government
(formerly GSA contracts.
Due to the large data volume, a software component for automatic updates of
Excluded
the SAM data in the Compliance application must be requested from AEB.
Party List
System) The operation at AEB on a dedicated installation may be necessary for high-
performance processing, which incurs additional costs.
Please contact AEB directly for prices and quotations. Get in contact via the AEB
website https://www.aeb.com or contact your AEB representative.

14
3.1.4 Japan lists
METI – Ministry of Economy, Trade and Industry

List Description Relevance Price Material

category number

EUL The End User List issued by Japan’s Ministry of Economy, Trade and Industry Screening against this list A D601017
End User List (METI) – lists the persons implicated in the development or construction of is relevant for companies
nuclear, chemical, or biological weapons or carrier missiles. that are subject to
Japanese law.

3.1.5 Switzerland lists

SECO – State Secretariat for Economic Affairs

List Description Relevance Price Material

category number

SECO This list contains persons and entities against which the United Nations, the Screening against this list A D601018
List of the Organization for Security and Cooperation in Europe, or the authorities of key is relevant for companies
Swiss State Swiss trading partners have decided to impose sanctions. that are subject to Swiss
Secretariat law.
for Economic
Affairs

15
3.1.6 Singapore lists
MAS – Monetary Authority of Singapore

List Description Relevance Price Material

category number

SG-MAS Persons providing financial services in Singapore are required to be licensed by Screening against the list A D601019
List of the the Monetary Authority of Singapore (MAS). The Investor Alert List provides a is not legally required,
Monetary listing of unregulated persons who, based on information received by MAS, may review at company’s
Authority of have been wrongly perceived as being licensed or authorized by the MAS. discretion
Singapore

3.1.7 Australia lists

DFAT – Department of Foreign Affairs and Trade

List Description Relevance Price Material

category number

AUCL This Australian list consolidates all persons, groups, and entities subject to UN Screening against this list A D601024
Australia Security Council sanctions or subject to targeted financial sanctions under is relevant for companies
Consolidated Australian sanctions law. that are subject to
List Australian law.

16
3.1.8 Further lists
United Nations Security Council

List Description Relevance Price Material

category number

UN Consolidated list of all persons, groups, and entities subject to UN Security Screening against this list A D601020
Consolidated Council sanctions. The consolidation is to facilitate the implementation of the is at the company’s
United measures introduced by the UN. The listed persons and entities are subject to discretion.
Nations various sanctions regimes that provide for different measures.
Security
Council
Sanctions List

The World Bank Group

List Description Relevance Price Material

category number

WBL The World Bank List is issued by the World Bank and lists the firms and Screening against the list A D601021
World Bank individuals classified as fraudulent or corrupt and therefore no longer deserving is not legally required,
List of subsidies. The listed firms and individuals are excluded from World Bank review at company’s
financing for the defined period. The purpose of this list is to fight fraud and discretion
corruption.

17
3.2 Lists by Reguvis (former Bundesanzeiger Verlag; subject to license fees)

List Description Price Material

category number

BANZEU The restricted party lists offered by Reguvis include the relevant EU financial sanctions (source: "Official A D601002
European lists Journal of the EU") and the publications in the "Bundesanzeiger".
BANZUS They are supplemented by the various lists recommended for consideration by the US Department of
US-American Commerce.
lists
Furthermore, the Reguvis data content includes the relevant lists from Japan, Australia, Canada, Switzerland,
BANZDIV the United Kingdom, and other national and international restricted party lists such as the UN Consolidated
Various lists Sanctions List
The complete (always up-to-date) overview of the lists offered by Reguvis can be found at: http://www.awr-
portal.de/SubBoy/pdf.jsp?site=ReadMe
You can purchase a license for these lists directly from Reguvis. Product information and contact details can
be found at https://shop.reguvis.de/data-content/datenservice-haddex-sanktionslisten/
In addition to the license from Reguvis, the data service for the automatic provision of the data from Reguvis
must be ordered from AEB. Please contact AEB directly for prices and quotations. Get in contact via the AEB
website http://www.aeb.com or contact your AEB representative.

18
3.3 Dow Jones content (subject to license fees)

List Description Price category Material number

DJ_* Dow Jones provides content on the following topics: SCO: B SCO: D601003
The name of l Global range of sanctions lists, watchlists, enforcement lists, etc. Watchlist (WL): C WL: D601006
this list
depends on l Special sanctions package "Sanctions Control & Ownership Feed (SCO)" for screening of the Trifecta: D Trifecta: D601004
the content indirect prohibition of provision and the 50% rule of the OFAC
package l Politically Exposed Persons (PEP) for screening and risk minimization in the areas of money
licensed with laundering and anti-corruption
Dow Jones. l "Adverse Media" to check negative media coverage of business partners
l “State Owned Companies” to screen and mitigate risk in the area of anti-corruption related to
state-owned companies
Dow Jones offers this content in the following sales packages:
l SCO
l Adverse Media
l State-Owned Companies
l Watchlist (contains SCO, PEP and global sanctions lists)
l Trifecta (contains all 4 single packages)
Due to the huge amount of data, it is necessary that you discuss with Dow Jones what content is
required exactly. You will license the Dow Jones content directly from Dow Jones. AEB will help you to
get in touch with a competent contact at Dow Jones who also knows about the integration with the
AEB software.
In addition to the license from Dow Jones a software component for automatic updates of the Dow
Jones data in the Compliance application must be requested from AEB. Please contact AEB directly for
prices and quotations. Get in contact via the AEB website https://www.aeb.com or contact your AEB
representative.

19
3.4 Can AEB provide the German BMWi Frühwarnhinweise via data service?
The “early warning notifications” by the German Federal Ministry of Economics (BMWi) are not public and will
only be made available to the companies by the respective Chamber of Commerce in charge.
Therefore AEB is not allowed by law to distribute this list. The early warning notifications are not a standard
offering of AEB's partners either.
If you receive early warning notifications from the Chamber of Commerce and would like to screen against
them using the AEB Compliance solution, you can import the addresses as a manual sanctions list in the
software.
AEB also offers the import of the early warning notifications as a service, which requires you to provide the
list of early warning notifications.

20
AEB SE
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[email protected] . Court of Registry: District Court of Stuttgart . HRB 767 414 .
Managing Directors: Matthias Kiess, Markus Meissner . Chair of the Board of Directors: Maria Meissner

Locations
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