Prohibited Parties, Debarment & Exclusion Lists
The United States Government prohibits U.S. companies and individuals from providing services of any kind to any foreign party shown on their Denied/Restricted Parties list. The Department of Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List is a list of terrorists, narcotics traffickers, and individuals or companies owned or controlled by targeted countries. U.S. companies and individuals are prohibited from doing business with or employing anyone who appears on the list.
We can also run HHS, GSA, FDA or other government exclusion or debarment checks on each of your applicants as they are initially screened. Additionally, we can perform required update searches monthly, quarterly or annually as needed on your entire employee population.
Below are some of the checks we can perform, but if you have one that is not on the list, please contact us to discuss your requirement.
Department of Commerce – Bureau of Industry and Security (BIS)
- Denied Persons List – Individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited.
- Unverified List – End-users who BIS has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction.
- Entity List – Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.
Department of State – Non-proliferation
- Nonproliferation Sanctions – Parties that have been sanctioned under various statutes.
Department of State – Directorate of Defense Trade Controls (DDTC)
- AECA Debarred List – Entities and individuals prohibited from participating directly or indirectly in the export of defense articles, including technical data and defense services. Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to “statutory debarment” or persons established to have violated the AECA in an administrative proceeding and subject to “administrative debarment.”
- Department of the Treasury – Office of Foreign Assets Control (OFAC)
- Specially Designated Nationals List (SDN) – Parties who may be prohibited from export transactions based on OFAC’s regulations.
FDA Debarment lists
- FDA Disqualified/Restricted/Restrictions Removed/Assurance Lists for Clinical Investigators
- FDA Debarment List (Drug Product Applications)
- FDA Debarment List (Food Importation)
FACIS® (Fraud and Abuse Control Information Systems)
- Fraud and Abuse Control Information Systems is a current and historical database of sanctions, exclusions, debarments and disciplinary actions for all provider types at federal and state levels
- Level 1: Searches against the OIG and GSA and other federal agency sources of information
- Level 2: This search sources included in Level 1 plus agencies operating in one selected state. This will be the state of the sanctioning agency, not necessarily the state in which the individual or entity resides.
- Level 3: Searches all state and federal sources included in the FACIS® database
U.S. Securities and Exchange Commission searches:
- FINRA’s Broker Check program
- Investment Adviser Public Disclosure (IAPD) Program.