Restricted Party List Screening in GTM Andrew Shang August 2012

Agenda • • • •

Overview How to trigger Restricted Party List Screening (RPLS) Service Preference and Service Parameter Different Types of RPLS

Agenda • • • •

Overview How to trigger Restricted Party List Screening (RPLS) Service Preference and Service Parameter Different Types of RPLS

Are you supposed to fulfill this order?

• Send 10 super computers to al-Qaeda, Afghanistan

RPLS Overview • U.S. individuals and companies are restricted or prohibited from exporting to any party contained in U.S. government export denial, debarment, and blocked persons lists. • Most of other countries have similar kind of regulations. • There are heavy penalties involved if you ship to a denied party, and could lead to denial or restriction of export privileges.

RPLS Overview • To screen all parties you are doing business with against the restricted party list, to stop transactions with restricted party involved

Contacts

Service Preference

Restricted Parties

Restricted Party Screening

Product Classification

RPLS in GTM footprint Classify

Screen

Execute

File / Report

Audit

Trade Transaction Management Global Data Model Trade Content Repository Configurable Rules Engine Document Generation and Repository

Cross Enterprise Visibility, Event Management, and Workflow Transportation Management

RPLS in GTM footprint

RPLS should happen when • • • • • • • • •

A Contact Master is created A Contact Master (inc. Location) is modified An Order is booked An Order is modified A shipment is created A shipment is modified Restricted Party List is updated A quotation is required etc

Agenda • • • •

Overview How to trigger Restricted Party List Screening (RPLS) Service Preference and Service Parameter Different Types of RPLS

How to trigger RPLS • • • • •

Ad-hoc User Action Agent Action Web Service Batch Process

Ad-hoc RPLS Ad-hoc restricted party list screening is performed using UI functionality. The typical use case for ad-hoc screening would be a request where no order or contact have been created. Example – Inquiry to determine if a job candidate is on a restricted list. Lets take the following example: An HR Manager asks the compliance group to review a job applicant, “Hilton Langley” to determine if he/she is on any restricted party list.

Ad-hoc RPLS • The compliance department runs a screening using the first and last name as shown below.

Ad-hoc RPLS • Screening matches are returned, as shown below

User Action Triggered RPLS

Contact

Transaction

Transaction Line

Agent Action Triggered RPLS

RPLS as Stand-alone Service • Steps: • Send a request to GTM • Request processed synchronously • GTM sends a response back

• No transaction data stored in GTM • No state in GTM • Optional service preference and service parameter can be specified in service request

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RPLS as Stand-alone Service

Sending System

ServiceRequest XML

GTM

Processed

ServiceResponse XML

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Batch Process Triggered RPLS

Agenda • • • •

Overview How to trigger Restricted Party List Screening (RPLS) Service Preference and Service Parameter Different Types of RPLS

Service Preference and Service Parameter • The configuration to determine the criteria of “Potential Match” and “No Match”

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Service Preference and Service Parameter • Case1: • Screening “HILTON LANGLEY” with the first and last name entered and country selected as USA and no service preference selected.

Service Preference and Service Parameter

• Case2:

• Screening “HILTON LANGLEY” with the first & last name entered, country selected as USA, and a service preference to screen by Company Name and Country (Match default is no match). • In this case NO matches are returned since the service preference created ignores the first and last name.

Service Preference and Service Parameter

• Case3:

• Screening with the company name entered as “NUCLEAR”, country selected as USA, first name as “HILTON”, last name as “LANGLEY” and selecting service preference to screen on Company Name and Country. • In this case matches are returned just for the company name and the country ignoring the first name and last name.

Agenda • • • •

Overview How to trigger Restricted Party List Screening (RPLS) Service Preference and Service Parameter Different Types of RPLS

Different Types of Restricted Parties • Government Lists • US, UK, etc

• Your or your client’s own “Black List” • Parties whom we don’t want to do business with

• Red Flag Words • “nuclear”, “chemical” and “biological”, etc

• Embargoed Countries • To set each Embargoed Country as a Restricted Party • An alternative to standard Embargoed Country Screening functionality

Government Lists • Bureau of Industry and Security (BIS) - denied parties, entities, unverified and embargoed. • Office of Foreign Assets Control (OFAC) - OFAC Sanctioned Countries • State Department - missile technology, debarred parties, designated terrorist organization, chemical & biological weapons, arms embargo

Government List

For Oracle employees and authorized partners only. Do not distribute to third parties. © 2010 Oracle Corporation – Proprietary and Confidential

Government Lists • Downloadable from CustomsInfo, which was originally from MK Denial • Updates are automatically downloaded every now and then • Usually kept in public domain as user are not supposed to edit them • Client can choose to download all lists or part of them

Dilemma – Name, Address or both? • If screening Full Name only, following may not be a match • Match if screening Address/City/Country without Name Contact

Restricted Party

Full Name

JENNY SMITH

WILLEM LOUW

Address

c/o: WILLEM LOUW 26 Andre Ave., President Ridge

26 Andre Ave., President Ridge

City

RANDBURG

RANDBURG

Country

SOUTH AFRICA

SOUTH AFRICA

Dilemma – Name, Address or both? • But if screening Address/City/Country only, following may not be a match, though the contact address is only one block away Contact

Restricted Party

Full Name

WILLEM LOUW

WILLEM LOUW

Address

1 Bridge Street

26 Andre Ave., President Ridge

City

RANDBURG

RANDBURG

Country

SOUTH AFRICA

SOUTH AFRICA

Dilemma – Name, Address or both? • If screening Full Name/Address/City/Country, following is still not a match, though the contact address is only one block away Contact

Restricted Party

Full Name

JENNY SMITH

WILLEM LOUW

Address

c/o: WILLEM LOUW 26 Andre Ave., President Ridge

26 Andre Ave., President Ridge

City

RANDBURG

RANDBURG

Country

SOUTH AFRICA

SOUTH AFRICA

Dilemma – Name, Address or both? • Solution: Screen twice. First time Full Name/ Country, Contact 2 matches. Second time Full Address/City/Country, Contact 1 matches. Contact 1

Contact 2

Restricted Party

Full Name

JENNY SMITH

WILLEM LOUW WILLEM LOUW

Address

c/o: WILLEM 1 Bridge Street LOUW 26 Andre Ave., President Ridge

26 Andre Ave., President Ridge

City

RANDBURG

RANDBURG

RANDBURG

Country

SOUTH AFRICA

SOUTH AFRICA

SOUTH AFRICA

Red Flag words • All examples below are considered as match • Red Flag word: Tehran

Contact 1

Contact 2

Contact 3

Company Name

University of Tehran

College of Engineering

College of Engineering

Address

Enqelab Ave

Enqelab, Ave, Tehran

Enqelab Ave

City Country

Tehran UAE

UAE

Red Flag words • Set up in Restricted Party

Red Flag words • Will the configuration below work?

• Answer: No!

Red Flag words • How about this?

• Answer: Yes!

Embargoed Countries • Standard Embargoed Country Screening on Contact Master • Set up Sanction Compliance Rule, Rule Set and Rule Set Group • Screen Contact Masters by the Sanction Rule Set Group either manually or by agent

Embargoed Country Screening • Embargoed Country Screening on Contact Master by RPLS • Set up Embargoed Countries as Red Flag words, e.g. Iran

Embargoed Country Screening • Embargoed Country Screening on Contact Master by RPLS • Contacts in Embargoed Countries will be caught as Red Flag word matches

Questions and Answers