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Automated screening tool (AST)
Software systems used by large financial institutions to facilitate the screening
process, as opposed to manual screening. In general, ASTs are designed to
screen against sanctions lists. ASTs generate hits against sanctions lists that
may be
consolidated into alerts based on, for example, a customer record. For one
customer record there may be multiple hits against sanctions lists that are
consolidated under one alert.
Autonomous sanctions
A single entity, whether a government or a coalition of governments, such as
the EU, acting to implement and enforce a sanctions regime. See "Unilateral
sanctions."
,Back-to-back letters of credit
A form of financing in which Bank A issues a letter of credit as collateral to
Bank B in order to issue a separate letter of credit to the beneficiary. This
often happens when the underlying agreement between the applicant and
beneficiary contains restrictions about the credit quality of the bank that is
issuing the letter of credit, the location of the issuing bank, or other
stipulations that prevent the applicant's bank
from issuing a direct letter of credit to the beneficiary. A sanctions evader
can use a back-to-back letter of credit to remove the name of a
sanctioned bank from the
documentation.
Batch screening
The process of screening a company's entire customer base and other
associated entities, such as vendors, with ASTs on a periodic basis.
Beneficial owner
The term "beneficial owner" has two different definitions depending on the
context: •
The natural person who ultimately owns or controls an account through which
a
transaction is being conducted • The natural people who have significant
ownership of, as well as those who exercise ultimate effective control
over, a legal person or
arrangement
,Bill of exchange
A shipping document that shows the means by which exporters are paid for
the goods that are to be shipped, including information such as the names
of the exporter, importer, issuing bank, and the bank where the funds will
be drawn.
Bill of lading
A required document that a carrier issues as a receipt of cargo. It includes
the type and quantity of cargo, as well as the destination.
Blacklist
An internal list of names (including places, persons, entities, and
individuals) that are screened to identify any sanctions exposure, in
addition to government and vendor- maintained sanctions lists. Other
potential additions to a company's internal blacklist may come from OFAC
advisories and other warnings that list entities that did not
merit being placed on the SDN list, but are still considered high risk. The FATF
blacklist is a list of countries that FATF has determined are
noncooperative in the international fight against money laundering and
terrorist financing.
Block
See "Asset freezing."
Blockade
The deployment of military resources by land, air, or sea, by a country or coalition to
prevent the movement of goods or people into or out of a targeted country.
, Boycott
A punitive withdrawal from business or social engagement with a government,
organization, or individual as a sign of protest.
Bureau of Industry and Security (BIS)
A section of the US Department of Commerce responsible for ensuring that
trade sanctions are properly understood, implemented, and enforced in the
United States. Among other tasks, the BIS regulates the import and export of
sensitive, dual-use,
and controlled goods and materials. The mission statement of the BIS is:
"Advance US national security, foreign policy, and economic objectives by
ensuring an effective export control and treaty compliance system and
promoting continued US strategic technology leadership."
Compliance
An action or state of adhering to a set of legislation, regulations, rules, policy,
specifications, or understood norms.
Comprehensive sanctions
Sanctions that prohibit all transactions and activity with a sanctioned country
by the sanctioning country except in rare, specific instances.
Consolidation of goods
A method of sanctions evasion in which a person or organization either
groups small shipments into one larger shipment or mixes restricted items
in with other goods and does not declare those restricted items in shipping
documentation.