Restricted Party Screening Guide
Restricted Party Screenings (“RPS”) module of Visual Compliance is used to ensure that the Lawrence Berkeley National Laboratory (“LBNL”) and its personnel are not interacting with restricted, denied, or debarred parties in violation of United States Export Control laws. Without proper authorization such as an export license, the government prohibits U.S. individuals and organizations from collaborating with or providing materials, software, services, and financial support etc. to these restricted parties. Various agencies within the U.S. Government maintain lists of restricted parties that include both foreign and domestic individuals (i.e. collaborators, researchers etc.) as well as organizations (i.e. universities, research institutions, public and private companies, banks, freight forwarders, vessels etc.). These lists are updated daily, so a valuable feature of Visual Compliance is their “Dynamic Screening” which continually rescreens all previous RPS against these updated lists.
Laboratory employees can register for an account with Visual Compliance to perform RPS. To register for an account, visit https://www.visualcompliance.com/usr and complete the user self-registration. When registering please be sure to use your complete LBNL email address and select the applicable division/functional area from the drop-down menu. Once registered, log into Visual Compliance and navigate to the RPS module. RPS module is also your default setting.
All parties to an engagement or a transaction must be screened. This includes both entities and individuals. RPS must be conducted using the complete name of the entity and individual. If you prefer, you may screen both the individual’s name and the associated company name on the same search. When performing screening, spell out acronyms and abbreviations.
“Exact” and “Fuzzy 2” searches are recommended screening options. However, in certain circumstances it may be best to use other search options. See section titled “Search Setting Options”.
NAVIGATE TO STANDARD SEARCH
PERFORM A RESTRICTED PARTY SCREENING
1. Name – Enter the individual’s complete first and last name. Do not include a middle name, manners
of address (Mr., Mrs., Dr., etc.), or degrees/credentials (M.D., Ph.D.) since there is uncertainty
around the Governments’ use of and style employed when adding entities to the restricted party lists.
2. Company/Organization/University – Enter the organization’s complete name. For example, please use “University of California” instead of “UC”.
3. Country – Enter the home country for the individual or company. If you know of multiple countries,
please run multiple screenings.
4. Comment – Enter your department, PI, and/or reason for screening. If you are performing test or practice screenings, please include the word “test” in the comment field so the screening can be removed from future screening.
5. Search Settings – Please use “Exact” and select all the options that are displayed on the screen shot above. Alternatively, you may use “Fuzzy 2” and not select “Stemming” and “Thesaurus”.
6. Screen – Click the “screen” button to perform the RPS.
SEARCH SETTINGS OPTIONS (FROM VISUALCOMPLAINCE.COM)
- An Exact Search looks for identical spelling in keywords, with some exceptions based on Search Modifications detailed below
- This is Visual Compliance’s most accurate and most popular Search Type, but there are certain situations when it is best to use another Search Type
- A Fuzzy Search finds common misspellings and typos
- Search fuzziness can be adjusted from 1 to 4, 1 being the least fuzzy and 4 being the most fuzzy, accommodating for a greater number of misspellings
- Fuzzy does not expand abbreviations, such as “University” for “Univ”
- Users might choose the Fuzzy Search when they are not confident in the spelling of the keywords they are screening
- Example: a Fuzzy Search for “Wayne Smyth” would trigger a match on “Wayne Smith”
- A Phonetic Search finds matches that “sound” like the keywords supplied, for all words supplied
- Phonetic uses the universal “Soundex” algorithm and does not substitute first characters. As such, it may not be reliable for transliterated names where, for example, one translator might use “Q,” another “K,” for the same sound at the beginning of the name
- Example: If you were asked perform a Phonetic search on the name “Mohammed,” Visual Compliance would also recognize the many spelling variations of the name (Mohamed, Mohamad, etc.)
- Stemming extends a search to cover grammatical variations on a word
- When Stemming is selected the search engine locates words with the same root, but different endings, such as -ed and -ing
- Example: A search for the word “apply,” also finds the words “applies,” “applied,” and “applying”
- Thesaurus searches synonymous values for proper names and geographic place names
- Thesaurus is not recommended for use with Fuzzy or Phonetic search. The Thesaurus check box is automatically cleared when the Fuzzy or Phonetic search is selected.
- Example: Screening the name “Bob” will also return matches containing “Robert” or “Rob,” and screening “Britain” will also return matches containing “England” or “U.K.”
- Selecting Field-Specific prevents keywords supplied from being screened against the “Notes” field in the database as well as the respective name, or company, city, state and country fields. De-selecting this option searches the keywords supplied in the result Notes as well as the regular fields
Remove business words
- Matching the form or style of business declarations (such as “Ltd,” “Co” or “GmbH”) can be problematic; for which Visual Compliance includes an implementation option to strip business declarations that is recommended for all users. Example: A search for “Acme Laboratories Limited” will not match if the official government form is “Acme Laboratories Inc.” The Remove Business Words modification equates the two expressions
It is important to remember that combining certain Search Types and Modifications can result in many more results than expected. Combining a Fuzzy Search with Stemming and Thesaurus might be considered “casting the net too wide” and return an unnecessary number of unrelated matches.
For example, screening “Bill” with Fuzzy, Stemming and Thesaurus could produce matches on “Bills,” “Bell,” “Bells,” “Bull,” “Bulls,” “Ball,” etc., as well as “Will,” “William,” “Billy,” “Willy,” “Willie,” and so on. The use of Stemming and/or Thesaurus is not suggested when using either the Fuzzy or Phonetic Searches.
NO MATCHES FOUND
If your screening produces “0 records returned” as shown below, and the individual/organization you screened is not from Belarus, Cuba, Iran, Syria, North Korea or Crimea, Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine please proceed with your transaction. If working with one of these countries, scroll down to “Country Alerts” section for guidance.
Stop, Review and Escalate (when necessary)
If your screening produces any matches as shown below, you need to PAUSE the transaction and evaluate it to determine whether the match is a positive match. If it is a positive match or if you are unsure as to the validity of the match, escalate the screening to your Division’s Export Control Liaison (“ECL”) found on the export control website at https://exportcontrol.lbl.gov/ or ECO at email@example.com. Please make sure to include the reason why you performed the screening and your concerns. The ECL or the ECO will review the screening and determine the appropriate next steps. Do not proceed with the transaction until the ECL or the ECO indicates that it is clear to proceed. All potential matches must be actioned in Visual Compliance in order to create the required record keeping audit trail.
Four audit trail options are available when resolving matched results.
Use “Clear” and add notes when you have determined that the RPS alert is a false positive.
Use “Action” and add notes when you intend to perform further follow up prior to resolving the alert.
Use “Escalate” and add notes when the RPS alert has been escalated for review.
Use “Closed” (available through the “Compliance Manager Workflow”) when the match is confirmed to be a positive match. Positive matches should be brought to the attention of the ECO.
Stop, Review and Clear
After careful review of your RPS alert, if you are able to determine that the resulting match is a false positive, you may proceed with your transaction by selecting “Clear” and documenting the reason for your actions in the notes field as shown below. All potential matches must be actioned in Visual Compliance in order to create the required record keeping audit trail.
If you choose to notify someone else of your actions on an RPS alert, you can choose “Save and Notify” option.
COUNTRY ALERT FOR BELARUS, CUBA, IRAN, NORTH KOREA, RUSSIA, SYRIA, AND CERTAIN REGIONS OF UKRAINE (Crimea, Donetsk People’s Republic (DNR) and Luhansk Peoples Republic (LNR)).
If your screening does not produce a match as shown below, but does produce a country alert for Belarus, Cuba, Iran, North Korea, Russia, Syria, or Crimea, DNR or LNR regions of Ukraine (comprehensively sanctioned or embargoed countries), you must escalate your screening to your ECL or the ECO for review. The ECL or the ECO will review and determine the appropriate next steps. Do not proceed with the transaction until the ECL or the ECO indicates that it is clear to proceed.
COUNTRY ALERT FOR ANY OTHER COUNTRY
If your screening does not produce a match, but does produce a country alert for any country other than the embargoed countries mentioned above, you are clear to proceed with your transaction unless it is an international shipment or another type of transfer of items or information. Please contact your ECL or the ECO to determine the appropriate next steps. Do not proceed with the transaction until the ECL or the ECO indicates that it is clear to proceed.
DYNAMIC SCREENING ALERTS
Dynamic Screening is a process in which any RPS performed from the Standard Search, Administrative Search, Multi-Party Search, and Batch Screening is rescreened. Searches are completed again each day against updates from the various restricted, denied, and sanctioned party lists to which your LBNL subscribes. Dynamic Screening uses your LBNL’s RPS Default Settings to determine new matches from existing parties. When a new match is received, by default a notice is sent to the email address of the user who performed the screening, and another email is sent to a designated email address which was previously defined. The designated email address is typically a group email address.
It is strongly recommended that each user group belonging to a specific division or functional area is represented with a group email address in Visual Compliance. As this feature enables dynamic alerts to be sent to the group email address, in addition to the person who originally performed the screening. If you are unsure as to whether your specific division or functional area is represented with a group email address, contact the Export Compliance Office (“ECO”) at firstname.lastname@example.org.
If you are unsure as to the validity of the match, escalate the screening to your Division’s ECL or the ECO for review and next steps. Please make sure to include the reason why you performed the screening and your concerns. The ECL or the ECO will review the screening and determine the appropriate next steps. Be prepared to take the recommended next steps if the alert turns out to be a positive match.
All dynamic screening alerts must be resolved on a regular basis using the “Compliance Manager Workflow” of Visual Compliance. Failure to resolve potential matches may result in unknowingly interacting with a restricted party. See section titled “Compliance Manager Workflow” for guidance.
COMPLIANCE MANAGER WORKFLOW
Compliance Manager Workflow can be used to view or manage RPS or Dynamic alerts, generate RPS audit logs and generate reports. It can be accessed from the drop-down menu on the right as shown below.
RPS ALERT MANAGEMNT
To view or manage RPS or Dynamic alerts, select “Full Review”. Next, select your search criteria and click on the search button as shown below. Be sure to select the appropriate date range. Use “Status” column to change status and “Add Notes”. See “Status Options” section for appropriate status selection.
Note that “Resolution Manager – Full Review” provides two date selection options. Namely, “Screening Date” and “New Match Date”. “Screening Date” is the date of the original screening. “New Match Date” is the date the dynamic alert was generated.
To view history of an alert, make selection from the “RPS Alert” column as shown below. Next, select “History” and expand on the entries by selecting the “+” sign.
DYNAMIC SCREENING MANAGEMENT
Daily Dynamic Screening alerts can also be resolved using the Compliance Manager Workflow. To do so, select your search criteria, select “DS New” to search for new dynamic alerts and run search as shown below. Be sure to select the appropriate date range. All dynamic screening alerts must be resolved on a regular basis using the Resolution Manager Workflow of Visual Compliance.
RESTRICTED PARTY SCREENING AUDIT
“Compliance Manager Workflow” provides auditing functionality for RPS. To run audits, select “Restricted Party Screening Audit” as shown below and select the search criteria.
Compliance Manager Workflow provides various report options. Reports can be generated by selecting “Summary” and selecting the type of report from the available options.
ADDITIONAL TRAINING RESOURCES
Visual Compliance provides its own training resources under each module. To access training navigate to the “Training” section as shown below.
Online help topics can be accessed using “Online Help” found next to the module selection at the top of the screen as shown below.