Table of contents
Objective and Scope
The objective of this operating procedure is to define roles, responsibilities and lead times for SBS, CCT(Customer, Credit and Trade Service Line) CTC (Customs and Trade Control), to provide the service of partners manual screening to the GBUs.
Partners manual screening is done for:
- Projected partners, wherever located before prospection, bid, sale, order approval, issuance of any purchase order or signature of any agreement;
- Business transactions where there is no link to any trade control IT tool (the distribution site Med-Lab ERP SAGE, R&I Solvay centres).
The group policy is turned towards the best level of compliance and the solution to ensure that the GBU shipments are authorized is to manually screen the recipients against restricted party lists and economic sanctions.
Effective date
October 1, 2018
Reviewed date
August 20, 2020
1. Context
2. Screening frequency
SBS, CCT, CTC will provide screening assessment on demand within 48 hours.
The agreed screening frequency between Med-Lab and SBS and Solvay R&I centres and SBS is for new customers when an account is opened within 24 hours and for all other customers at least once every 12 months.
3. Operation sequence
Mandatory fields for an efficient screening:
- full name of the recipient;
- the country of destination;
- the End Use Statement (if required) (see Appendix 32 ).
The GBU will have to check in advance whether the destination country is listed as a "country at risk", see Appendix 07 of the Group Export Compliance Program (GECP). Any shipment to a country at risk will require a Compliance Statement, see Appendix 11 of the GECP.
CTC Customs specialists perform screening of the account through Dow Jones' "Risk and Compliance" and "Factiva" solutions, which contains two main parts as follow:
- Sanctions Lists : more than 800 sanctions lists (UN, US and EU consolidated lists, Interpol, FBI, etc.) including ownership research and links to Politically Exposed Persons and Special Interest Persons.
- Adverse Media : more than 1 billion reliable news stories articles including 35 years of archives (over 42% is not freely available on the web) on corruption, financial crime, competition, human rights, and much more.
SBS, CCT, CTC answers back to the requestor's email and provides the approved/denied result.
The analysis includes:
- the partner screening report from Dow Jones with analysis in case of sanctioned partners;
- the Dow Jones credentials to access the adverse media news if any;
- the verification and approval/denial of the End Use Statement.
CTC Customs specialists perform batch screening of existing customers on Dow Jones Risk and Compliance at least every 12 months for both Med-Lab and Solvay R&I centers.
Any issues related to trade control has to be reported to the GBU Empowered Official.
For urgent request, outside of Portugal time zone (GMT+1) and which cannot wait a response time of 12 hours, GBU should contact CTC backup contacts as follows:
ZONES | SBS MEMBER | TELEPHONE | |
AMERICAS | Janice Sarmiento | 001 (609) 6199 814 | |
APAC | Cindy Xiong | 00862 123 502 299 | |
Teresa Liang | 00862 123 502 123 |
CTC Process Expert audits the process once per year.
4. Roles and responsibilities
Actor | Role | Responsibility |
|---|---|---|
| GBU | Site | verifies the country of destination and request an End Use Statement when required |
| GBU | Site | sends emails to CTC with new account details for manual screening along with a copy of the End Use Statement if needed |
| CTC | Customs specialists | daily check of the new accounts to be analyzed |
| CTC | Customs specialists | analyze new partners in Dow Jones and follow internal procedure in case of perfect match |
| CTC | Customs specialists | analyze, approve/deny End Use Statements for accounts located in countries at risk |
| CTC | Process Expert | provides support for the license determination |
| CTC | Customs specialists | answer back to the GBU, within 24 hours for Med-Lab and R&I centres or within 48 hours for other requests, after email reception and provide account status (approved or denied) |
| CTC | Customs specialists | archive the screening analysis with resolution case on Risk and Compliance |
| CTC | Customs specialists | perform batch screening of existing customer on Dow Jones Risk and Compliance at least every 12 months for both Med-Lab and Solvay R&I centers |
| GBU | Empowered Official | manages non compliance issues related to the site |
| CTC | Process Expert | supports CTC specialists and audits the process once per year |
Scope
Worldwide
Dow Jones
ERP
References
Attachments
Scope
UK
ERP
SAGE
Dow Jones
References
Attachments
ANNEX:
1- End Use Policy
https://drive.google.com/drive/folders/1I9wFaJY3RkhiZOOxfLNJCH9M9WYkqpPQ