In recent years, increased government regulations—both U.S. and international—dictating with whom organizations can and cannot do business have made it more and more difficult for companies to remain compliant. Businesses today must check their customers, contacts, leads, accounts, vendors and suppliers against hundreds of government watch lists.
That’s daunting in and of itself, but when you factor in that these lists change frequently, sometimes daily, and that companies must also keep audit records of their due diligence, it’s enough to give most people a headache. But there are ways to ensure your business is not violating any U.S. export laws and regulations. Sure, you could do it manually, but you could be missing out on better accuracy and efficiency. For best results, don’t just screen–screen SMARTLY. And do it directly in Salesforce®.
Search refinement settings are your best friends. If you’re using a denied party screening software tool, such as Visual Compliance™–Verification for Sales, you can reduce false positives (who has the time to wade through hundreds of unwanted names?), and also ensure you’re not missing alerts due to typos or names with multiple possible spellings. You can maximize screening efficiency by understanding what various settings do, determine when you should use them and when it would be more efficient to turn them off. Among your options: grammatical variations on a word (like “s” or “ed” endings), synonyms of a name, or even matches that simply sound like your searched term.
Mind the three Ws of screening:
- Who to screen. International customers may be obvious, but what about domestic customers that re-export internationally? What about your employees, resellers and distributors? And your Salesforce® Leads, Contacts and Accounts? Take a good look at all the parties with whom you connect, and make sure nobody is overlooked.
- When to screen. It should be done before signing a contract with a new customer or manufacturer—and periodically thereafter throughout the life cycle of your business relationship.
- What to enter in the search fields. When using a software solution, be strategic and select parameters in all possible fields—such as City, State and Company—to assure the quality of matches returned.
Audit recording is essential. You can screen until the cows come home, but in an audit, if there’s no record of your denied or restricted party screening activity it’s as though it never happened. Details about who you screened, when you screened and the result of that screening are integral not only to passing your audit but to avoiding internal oversights and miscommunication. Conscientious day-to-day screening keeps your transactions legal, but don’t neglect your responsibility to prove your due diligence.
Rescreen daily. Once you’ve screened and received the all-clear on your party, it’s tempting to high-five your colleagues and add to your “done” pile. But no denied party screening is ever really “done” so long as you’re still doing business with the individual or company in question. Government watch lists change often—even a long-time employee or customer can suddenly appear as a denied party—and regular rescreening is the only way to know your transactions are compliant each and every time.
Timeliness is everything. You need access to the most current, up-to-date sanctioned and denied party lists or your screening results simply can’t be trusted. Receiving updates as they are published by the government and other official bodies is your best bet.
List selection matters. You may think screening against every list available is wise, but by doing so you’re actually inviting invalid matches. Pare down the number of lists you use by doing some self-examination of your industry, where your Salesforce® Leads, Contacts and Accounts are located, and the products you export. If, for example, your company does not deal with government contracts of any kind, screening against the General Services Administration (GSA) List is unnecessary.
Your escalation process is integral. Smart screeners have an incident management plan in place for when denied party screening yields a match. They ensure decision-makers receive all the details required to investigate and clear transactions with minimal delay. After all, postponing lawful shipments won’t endear you to impatient customers. Conversely, if there’s a true threat of violation, immediately stopping the transaction. Many companies use email alerts as a reliable communication channel to keep the right people in-the-know. Visual Compliance–Verification for Sales, for example, does just that by sending email notifications in real time to those who need to be in the know. Thoroughly detailed notes regarding your incident response activities are a must so that facts are clear and decisions are defensible in case of an audit.
Solid compliance programs demand smart screening. How does your current process measure up?