Webinar deck for legal basics and best strategy for compliance screening presented by AEB.

1. Legal basics and best
strategy for compliance
screening
AEB webinar . November 9, 2022
AEB SE . 2022
This webinar will be recorded

2. Your hosts today
Matthias Wenning
Training Specialist
Key Speaker
Olga Pramberger
Export Control & Sanctions
Q&A
Nicole Mantei
Product Management
Q&A
Tatjana Schork
International Marketing
Moderator

3. Cloud solutions fine-tuned to your business
Customs Management
Export Filing & Import Filing
Customs Broker Integration
Product Classification
Origin & Preferences
Supplier Declaration Exchange
EMCS Filing
Trade Compliance
Compliance Screening
Product Classification
Export Controls
License Management
Risk Assessment
Logistics & Supply Chain
Carrier Connect
Freight Cost Management
Transport Management
Warehouse Management

4. Cloud solutions fine-tuned to your business
Customs Management
Export Filing & Import Filing
Customs Broker Integration
Product Classification
Origin & Preferences
Supplier Declaration Exchange
EMCS Filing
Trade Compliance
Compliance Screening
Product Classification
Export Controls
License Management
Risk Assessment
Logistics & Supply Chain
Carrier Connect
Freight Cost Management
Transport Management
Warehouse Management

5. 1. Legal basics
2. Software demo
3. Questions & answers

7. Restricted party list screening
Check name
Software task
The software compares:
Name of your business
partner with names
of the entities in the stored
sanctions lists.
Reports a hit in case of a
match.
Check match
Manual task
Is there a personal identity?
Is the checked business
partner really the listed
person or organization?
Personal identity
(-) NO – “no real match”
→ define a “Good Guy”
→ Release
Further action
Manual task
Personal identity
(+) YES – “real match”
If the transaction is within
the scope of the list, legal
consequences must be
respected.
→ Take internally defined
measures.
Documentation
Software task
The software logs all results.
Including the meaningful
description of the decision that
was taken regarding the
handling of the match.
What does it include?

8. EU bans on the provision of resources
Bans on the provision of resources in EU sanctions regulations
→ No financial resources for unlawful actions
Anti-terrorism regulations
• Al-Qaeda, IS
• Taliban
• Other terrorist groups
Bans on the provision of
resources to terrorists
and terrorist groups
Countries – embargoes
• Russia
• Iran
• Syria
• etc.
Bans on the provision of
resources to natural/legal
persons and organizations in
the sanctioned countries
Country-independent sanctions
• Prevention of
chemical weapons
• Measures against
cyber attacks
• Measures against
human rights violations
Bans on the provision of
resources to natural/legal
persons and organizations

9. What is the scope of financial sanctions?
Bans on the provision of resources
No funds or economic resources shall be
made available, directly or indirectly, to or for
the benefit of the designated natural or legal
persons, entities or bodies
Asset Freeze
Concerns financial sector
Definition ‘economic resources’
means assets of every kind, whether tangible or intangible, movable or immovable, which are not
funds but may be used to obtain funds, goods, or services
Under financial sanctions, anything that can be attributed to the assets of a
person, or a company is subject to bans on the provision of resources.

10. EU: Screening against the CFSP list
• CFSP list – official EU database
• Consolidation of ALL persons, companies,
and organizations with bans on provisions
by the EU in the CFSP list
CFSP list

11. • UK Sanctions List includes those designated parties
under regulations made under the Sanctions Act (link)
• OFSI Consolidated List includes all UK financial
sanctions listings (link)
• List of persons named in relation to financial and
investment restrictions under the Russia (Sanctions)
(EU Exit) Regulations 2019 ensuring that Russia-related
sanctions are implemented effectively (link)
UK: Screening against the UK Sanctions List

12. US: Screening against US lists from OFAC and BIS
Office of Foreign Assets Control (OFAC)
Sanctions lists managed by OFAC
Specially Designated
Nationals (SDN) List
• in principle only relevant
for US persons
• Suffixes [NPWMD],
[SDGT], [SDT], [FTO],
[IRAQ2] relevant for non-
US persons when dealing
with US products
• Consider Secondary
Sanctions for non-US
persons [IRAN] and
miscellaneous E.O.
[UKRAINE].
Sanctions lists managed by
the Bureau of Industry and
Security (BIS) when dealing
with US products (items
subject to the EAR)
• Denied Persons List
• Unverified List
• Entity List
• Military End User List
Bureau of Industry
and Security (BIS)
OFAC Consolidated
Sanctions List
(non SDN Lists)
(Secondary Sanctions E.O.
[UKRAINE13662]
Important:
US law is
extraterritorial!

13. • Sanctions lists exist in a number of other countries
• METI (Ministry of Economy, Trade and Industry) End User List in Japan
• SECO (State Secretariat for Economic Affairs SECO) List in Switzerland
• “Registre national des gels” in France
• “Nationale sanctielijst terrorisme” in the Netherlands
• DFAT (Department of Foreign Affairs and Trade) Consolidated List in Australia
• …..
• These lists must only be checked by companies that are subject
to the respective law
Example: A company established under Japanese law should check the METI EUL list,
while an Austrian company should not.

14. • You are legally required to comply with applicable sanctions
• Independent assurance of compliance is required (regardless of how)
• Each individual company is responsible for implementing such assurance
• Internal processes must be defined according to company-specific structures
• There is no standard format for Internal Compliance Programs (ICP) – but various
authorities make guidelines available (learn more here)
• Both overregulating and underregulating is to be avoided
• Automated sanction lists screening is acknowledged by authorities as
the effective way to ensure compliance with financial sanctions

16. AEB
Plug-in
Standardized
Salesforce integration
via plug-in
AEB
Plug-in
Integration options for host systems
Standardized SAP®
integration via
plug-in
Optional interface
for file uploads
Manual data entry
for online quick
checks
Transactional checks in other
systems via standard API/web
service
INFOR IFS MSD
365
Other
AEB Cloud
Trade Compliance
Compliance Screening

17. … and now let’s see how
best practice looks like.

19. Thank you for your
attention!
www.aeb.com/compliance
www.aeb.com/newsletter
AEB SE . 2022

20. www.aeb.com