Sanctions and Restricted Party Lists
There are many known entities of concern in China and Russia which are involved in weapons of mass destruction, military, and other end uses of concern. There are no UN sanctions in place given that both countries are veto-wielding members of the UN security council. However, other individual countries have identified entities of concern in their national sanctions lists. This includes the sanctions lists of the US, EU and Japan. The basis of adding entities of concern to such lists varies from country to country and the inclusion of an entity on such a unilateral sanctions list is not binding to entities operating outside the relevant jurisdiction. Nonetheless, the inclusion of any entity in such a list is a clear indicator that there is a risk associated with commerce with the entity. Companies should thus use such lists as part of a risk management approach. This implies screening customers and partners against such lists and taking a considered approach about what to do when a potential customer or partner is listed. The inclusion of an entity on such a list may be grounds to assert that a company ‘knew or had reason to know’ that there was a military or WMD related concern with the party. It may be beneficial or necessary to refer the case to relevant national authority for guidance on whether a weapons of mass destruction or military end use control would be applied.
- EU consolidated sanctions list
- US non-SDN list
- US SDN list
- US entity list
- UK sanctions list
- Australian sanctions list
- Canada sanctions list
- Japanese METI List
Media and NGO Resources
As with lists of sanctioned entities, you should know if a customer on partner on a dataset of entities of concern published by a media outlet or an NGO. Inclusion of an entity in such a list does not necessarily mean that business should not be conducted. Instead, it is a potential indicator of risk that should be systematically assessed and managed. It is possible that inclusion of an entity on such a database would be grounds for you to know or have reason to know of a WMD or military related end use in a transaction, although it is perhaps less likely than if the entity was listed by a government or international organizations.