In the complex landscape of international sanctions, the Foreign Sanctions Evaders (FSE) List stands out as a crucial tool in enforcing U.S. sanctions against entities involved in illicit activities, particularly concerning Iran and Syria. Established by the Office of Foreign Asset Control (OFAC), this list comprises individuals, businesses, and other entities found to have violated or abetted violations of U.S. sanctions.
For U.S. individuals and businesses, compliance with the FSE List is not optional—it’s mandatory. Any engagement with entities on this list is strictly prohibited, with severe penalties for non-compliance. Entities subject to sanctions on the FSE List span various sectors, from banks to cryptocurrency exchanges, making routine screening against this list imperative to mitigate the risk of sanctions violations.
Sanctions Against Iran and Syria:
Syria and Iran have long been targets of U.S. sanctions, with efforts to evade these sanctions prompting the creation of the FSE List. Sanctions against Syria date back to the late 1970s, intensifying with subsequent executive orders. Similarly, Iran faces broad sanctions aimed at restricting exports and access to the U.S. financial system, with specific measures targeting entities involved in terrorism and human rights abuses.
Executive Order 13608 and the FSE List:
To combat the evasion of sanctions by non-U.S. entities, Executive Order 13608 empowered OFAC and the Justice Department to publicly identify and sanction foreign individuals involved in violating U.S. sanctions against Iran and Syria. Introduced in 2014, the FSE List consolidates the identities of such entities, facilitating enforcement actions against them.
Working with FSE-listed Entities:
Entities listed on the FSE List are off-limits for U.S. businesses. Prohibited activities include any form of transaction, direct or indirect, involving listed individuals or entities. This prohibition extends to financial services, with stringent requirements for reporting any attempted transactions involving listed parties.
Scope of FSE Sanctions:
Contrary to common misconception, FSE sanctions are not limited to transactions related solely to Iran and Syria. Any relevant transaction with listed entities, regardless of location or nature, falls under the purview of these sanctions. The primary objective is to deprive sanctions evaders of access to the U.S. financial system.
FSE List vs. SDN List:
While both the FSE List and the Specially Designated Nationals (SDN) List serve to safeguard U.S. interests, they differ in focus. While the SDN List encompasses individuals and entities posing threats to U.S. interests globally, the FSE List specifically targets violators of sanctions against Iran and Syria. However, some entities may appear on both lists due to overlapping activities breaching U.S. sanctions law.
Sanctions Screening for FSE-listed Entities:
Effective compliance necessitates thorough screening of new and existing customers against the FSE List and other OFAC and international sanctions lists. Alessa’s Watchlist and Sanctions Screening Software offers robust solutions for fast, accurate OFAC sanctions screening, featuring global PEP and sanctions screening, real-time monitoring, configurable workflow management, and a proprietary PEP Scoring Model to reduce false positives.
In conclusion, navigating the intricate landscape of international sanctions requires diligent compliance efforts. By understanding and adhering to regulations surrounding the FSE List, businesses can safeguard their operations and reputation while contributing to global security and stability. Contact Us to learn more about Ahrvo Comply.
