Debarment and OFAC

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CVM Risk and Compliance Data services facilitate compliance with certain government regulations and thus minimize overall compliance risk to customers. In addition, market conditions and volatility requires a high level of due diligence to minimize exposure and loss. Besides compliance implications, there is a significant impact to the company’s reputation in the marketplace.

OFAC

As part of its enforcement efforts, the U.S. Department the Treasury, Office of Foreign Assets Control (OFAC) publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDN." Their assets are blocked and U.S. persons are generally prohibited from dealing with them.

CVM will screen all suppliers against the OFAC/SDN list as part of the data services being provided. CVM provides various subscription options as part of the OFAC data service:

  • Real Time OFAC Enrichment – CVM Vendor Central is integrated with CVM’s OFAC real time data service (Web service), to enrich against the list of specifically designated nationals and blocked persons. For each supplier, the match score and enrichment date will be maintained in the database. This data will be available for searching and the results will be saved for audit purposes.
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  • Quarterly Enrichment – Along with other quarterly data enrichment services, the supplier base will be enriched on a quarterly basis against OFAC list. Matched suppliers with a certain threshold score will be stored in the data-base for future access.
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  • OFAC Alerts and Notification – CVM supports an OFAC alert notification. As the SDN list gets updated, a notification would be sent out to a designated email address.

Debarment List (EPLS)

CVM also provides data enrichment to include debarment (EPLS) data.

The Excluded Parties Listing Systems (EPLS) is the Lists of Parties Excluded from Federal Procurement and Non-procurement Programs (Lists), which identifies those parties excluded throughout the U.S. Government from receiving Federal contracts or certain subcontracts and from certain types of Federal financial and nonfinancial assistance and benefits. This list is maintained by the GSA (General Services Administration).

Organizations that are recipient of government contracts and others have internal processes in place to ensure that they do not conduct business with entities or individuals in this published list. CVM provides enrichment against this list and provides any matches found. The matches will indicate the CT code (Cause and Treatment code), indicating why the entity was debarred.