cindy peeters dps presentation 111004

8/20/2019 Cindy Peeters DPS Presentation 111004

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Denied Party ScreeningDenied Party Screening

Best PracticesBest Practicesby Cindy Peetersby Cindy Peeters

Millitech, Inc.Millitech, Inc.

Technology Control Technology ControlOfcer/Facility Security OfcerOfcer/Facility Security Ofcer


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Screening is theScreening is the

oundation o e!ecti"eoundation o e!ecti"e

co#$lianceco#$liance


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Millitech %istoryMillitech %istory Millitech designs and #anuactures #illi#eter&Millitech designs and #anuactures #illi#eter&

'a"e co#$onents and syste#s or both'a"e co#$onents and syste#s or bothco##ercial and #ilitary a$$lications.co##ercial and #ilitary a$$lications.Custo#ers include (aytheon, B)*, +ocheed,Custo#ers include (aytheon, B)*, +ocheed,

Boeing, (oc'ell, and all the other #a-orBoeing, (oc'ell, and all the other #a-ordeense contractors.deense contractors.

Foreign o'ned, o$erate under an SS) so 'eForeign o'ned, o$erate under an SS) so 'ecan #aintain our security clearance.can #aintain our security clearance.

e ha"e a large international business ande ha"e a large international business and

ha"e #any licenses T))0s.ha"e #any licenses T))0s. Denied $arty screening is essential in e"eryDenied $arty screening is essential in e"ery

as$ect o our business.as$ect o our business.


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KNOW YOUR CUSTOMERKNOW YOUR CUSTOMER

1.S. e2$ort controls la's and regulations $rohibit1.S. e2$ort controls la's and regulations $rohibite2$orters ro# entering into a transaction 'ithe2$orters ro# entering into a transaction 'ithno'ledge that a "iolation o those la's has occurredno'ledge that a "iolation o those la's has occurredor is about to occur. They also contain $rohibitionsor is about to occur. They also contain $rohibitionsagainst doing business 'ith certain s$eci3ed $ersonsagainst doing business 'ith certain s$eci3ed $ersonsand certain countries4 e2$orting to $rohibited end&usesand certain countries4 e2$orting to $rohibited end&usesor end&users4 and contributing to the $rolieration oor end&users4 and contributing to the $rolieration o'ea$ons o #ass destruction and deli"ery syste#s. To'ea$ons o #ass destruction and deli"ery syste#s. Toa"oid "iolating these $rohibitions, an e2$orter #usta"oid "iolating these $rohibitions, an e2$orter #ust#ae sure they are not dealing 'ith a restricted $arty#ae sure they are not dealing 'ith a restricted $artyor $ossible $rolierators. In short,or $ossible $rolierators. In short, e2$orters ha"e ae2

$orters ha"e aduty to e2ercise 5reasonable care6du

ty to e2ercise 5reasonable care6 in in"estigating thein in"estigating the$arties in"ol"ed in, and the nature o, its e2$ort$arties in"ol"ed in, and the nature o, its e2$orttransactions.transactions.


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7uestions to as yoursel 7uestions to as yoursel

)re you screening8)re you screening8

hy are youhy are you

screening8screening8 ho is screening8ho is screening8

%o' are you%o' are you

screening8screening8 hat are youhat are you

screening or8screening or8

ho are youho are you

screening8screening8

hen are youhen are youscreening8screening8

%o' oten are you%o' oten are you

screening8screening8


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Suggested PracticeSuggested Practice


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)s you can see, e"ery)s you can see, e"ery

"isitor in our co#$any"isitor in our co#$anyhas to co#e throughhas to co#e throughthe ront door, gothe ront door, gothrough DPS and bethrough DPS and be

badged. e start thebadged. e start the$rocess early.$rocess early.

F9I : 'e did notF9I : 'e did notconduct DPS on ;conduct DPS on ;

'ee old Baby Brody,'ee old Baby Brody,but 'e did or hisbut 'e did or his#o#.#o#.


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DPS ProcessDPS Process


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+ists to Chec+ists to Chec

+ists to chec+ists to chec

include


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hat are (ed Flags8hat are (ed Flags8

Possible indicators that an unla'ulPossible indicators that an unla'uldi"ersion #ight be $lanned by thedi"ersion #ight be $lanned by the

custo#ercusto#er )bnor#al or sus$icious circu#stances)bnor#al or sus$icious circu#stances

There are ob"ious red >ags and not so ob"ious There are ob"ious red >ags and not so ob"iousred >ags. Most $eo$le that 'or in co#$liancered >ags. Most $eo$le that 'or in co#$liance

tend to ha"e a gut eel 'hen they thintend to ha"e a gut eel 'hen they thinso#ething is 3shy. ?o 'ith that eeling and doso#ething is 3shy. ?o 'ith that eeling and doyour best due diligence to ee$ your co#$anyyour best due diligence to ee$ your co#$any

out o -eo$ardy.out o -eo$ardy.


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*2a#$les o (ed Flags*2a#$les o (ed Flags

The custo#er or its address is si#ilar to one o the $arties The custo#er or its address is si#ilar to one o the $artiesound on one o the denied $erson0s lists.ound on one o the denied $erson0s lists.

The custo#er or $urchasing agent is reluctant to o!er The custo#er or $urchasing agent is reluctant to o!erinor#ation about the end&use o the ite#.inor#ation about the end&use o the ite#.

The $roduct@s ca$abilities do not 3t the buyer@s line o The $roduct@s ca$abilities do not 3t the buyer@s line obusiness, such as an order or so$histicated co#$uters or abusiness, such as an order or so$histicated co#$uters or as#all baery.s#all baery.

The ite# ordered is inco#$atible 'ith the technical le"el o The ite# ordered is inco#$atible 'ith the technical le"el othe country to 'hich it is being shi$$ed, such asthe country to 'hich it is being shi$$ed, such asse#iconductor #anuacturing eAui$#ent being shi$$ed to ase#iconductor #anuacturing eAui$#ent being shi$$ed to a

country that has no electronics industry.country that has no electronics industry. The custo#er is 'illing to $ay cash or a "ery e2$ensi"e The custo#er is 'illing to $ay cash or a "ery e2$ensi"e

ite# 'hen the ter#s o sale 'ould nor#ally call orite# 'hen the ter#s o sale 'ould nor#ally call or3nancing.3nancing.

The custo#er has little or no business bacground. The custo#er has little or no business bacground.


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*2a#$les o (ed Flags*2a#$les o (ed Flags

cont0dcont0d The custo#er is una#iliar 'ith the $roduct@s $eror#ance The custo#er is una#iliar 'ith the $roduct@s $eror#ance

characteristics but still 'ants the $roduct.characteristics but still 'ants the $roduct. (outine installation, training, or #aintenance ser"ices are(outine installation, training, or #aintenance ser"ices are

declined by the custo#er.declined by the custo#er. Deli"ery dates are "ague, or deli"eries are $lanned or out oDeli"ery dates are "ague, or deli"eries are $lanned or out o

the 'ay destinations.the 'ay destinations. ) reight&or'arding 3r# is listed as the $roduct@s 3nal) reight&or'arding 3r# is listed as the $roduct@s 3nal

destination.destination. The shi$$ing route is abnor#al or the $roduct and The shi$$ing route is abnor#al or the $roduct and

destination.destination. Pacaging is inconsistent 'ith the stated #ethod o shi$#entPacaging is inconsistent 'ith the stated #ethod o shi$#ent

or destination.or destination. hen Auestioned, the buyer is e"asi"e and es$ecially unclearhen Auestioned, the buyer is e"asi"e and es$ecially unclear

about 'hether the $urchased $roduct is or do#estic use, orabout 'hether the $urchased $roduct is or do#estic use, ore2$ort, or or re&e2$ort.e2$ort, or or re&e2$ort.


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%its or Matching (ecords%its or Matching (ecords

When DPS Results in “Hits”When DPS Results in “Hits” (ead and chec the detailed results(ead and chec the detailed results In"estigate and e2clude any $ossibility o a coincidence or aIn"estigate and e2clude any $ossibility o a coincidence or a

si#ilar sounding na#e or entity.si#ilar sounding na#e or entity. (e"ie' the citation. There are instances 'here a na#e/entity(e"ie' the citation. There are instances 'here a na#e/entity

and citation #ay result in a #atch, but the citation does notand citation #ay result in a #atch, but the citation does not$rohibit this $articular business transaction.$rohibit this $articular business transaction.

eriy the na#e/entity, address, and citation using the DPSeriy the na#e/entity, address, and citation using the DPSeri3cation State#ent or# to docu#ent due diligence.eri3cation State#ent or# to docu#ent due diligence.

eri3cation should include at a #ini#u# the co#$letion o theeri3cation should include at a #ini#u# the co#$letion o theDPS eri3cation State#ent or# in 'hich the na#e/entity, date,DPS eri3cation State#ent or# in 'hich the na#e/entity, date,signature and state#ent o the indi"idual attesting they are notsignature and state#ent o the indi"idual attesting they are note2cluded ro# 1S go"ern#ent e2$ort/i#$ort acti"ity ande2cluded ro# 1S go"ern#ent e2$ort/i#$ort acti"ity andre-ecting being a denied $arty are included along 'ith a co$y o are-ecting being a denied $arty are included along 'ith a co$y o adri"er0s license, $ass$ort, or "isa, i a$$licable. ) te#$late isdri"er0s license, $ass$ort, or "isa, i a$$licable. ) te#$late is

a"ailable.a"ailable. (ecord and 3le the "eri3cation state#ent and all rele"ant(ecord and 3le the "eri3cation state#ent and all rele"ant

co##unication.co##unication. Proceed 'ith the business transaction.Proceed 'ith the business transaction.

I "eri3cation cannot be obtained or the $arty is un'illing toI "eri3cation cannot be obtained or the $arty is un'illing to$ro"ide the necessary inor#ation, it is suggested to sus$end$ro"ide the necessary inor#ation, it is suggested to sus$endacti"ity until there is coo$eration, or ter#inate the acti"ity.acti"ity until there is coo$eration, or ter#inate the acti"ity.


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DPS eri3cation State#entDPS eri3cation State#ent

I,_________________ , certify that I am not the same person(s) orI,_________________ , certify that I am not the same person(s) orentity listed on the denied party screening performed by Millitech.entity listed on the denied party screening performed by Millitech.Further, I certify that I am presently not facing any penalties orFurther, I certify that I am presently not facing any penalties orhave aected privileges with the .!. "overnment regardinghave aected privileges with the .!. "overnment regardinge#port$import regulations. Millitech has provided a printout of thee#port$import regulations. Millitech has provided a printout of thelist of name(s) and$or address(es) which resulted from conductinglist of name(s) and$or address(es) which resulted from conductingmy name$entity search, and I verify that the names$entity,my name$entity search, and I verify that the names$entity,residences, and aected privileges have no relation to me.residences, and aected privileges have no relation to me.

%rior to entering the facility and$or proceeding with a business%rior to entering the facility and$or proceeding with a businesstransaction$activity, I have provided Millitech a copy of my driver&stransaction$activity, I have provided Millitech a copy of my driver&slicense (or 'isa$%assport) which Millitech will eep in their les forlicense (or 'isa$%assport) which Millitech will eep in their les forverication and record eeping purposes only.verication and record eeping purposes only.

=a#e


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Direct %its e2act #atchDirect %its e2act #atch

When DPS Results in a “Direct Hit” (name anWhen DPS Results in a “Direct Hit” (name ancitati!n a""lica#le$citati!n a""lica#le$

(ead and chec the detailed results.(ead and chec the detailed results. eriy it is a direct hit. =otiy TCO.eriy it is a direct hit. =otiy TCO.

Sus$end the transaction or acti"ity $rocessSus$end the transaction or acti"ity $rocess Inor# the custo#er/"isitor the transaction is on 5hold6 $ending aInor# the custo#er/"isitor the transaction is on 5hold6 $ending a

urther detailed in"estigation o e2$ort/i#$ort co#$lianceurther detailed in"estigation o e2$ort/i#$ort co#$liance#atters and that there #ay be a delay or $rolonged $rocess#atters and that there #ay be a delay or $rolonged $rocessti#es.ti#es.

Do not a$$ro"e orders, sign o! or#s, release shi$#ents orDo not a$$ro"e orders, sign o! or#s, release shi$#ents orauthorie e2$orts or "isits.authorie e2$orts or "isits.

(ecord and 3le all docu#entation.(ecord and 3le all docu#entation. =otiy the $arty that this transaction cannot be co#$leted=otiy the $arty that this transaction cannot be co#$leteddue to e2$ort/i#$ort co#$liance #atters.due to e2$ort/i#$ort co#$liance #atters.

It is reco##end that this co##unication be docu#ented andIt is reco##end that this co##unication be docu#ented and3led 'ith DPS related records or uture reerence.3led 'ith DPS related records or uture reerence.

STOP )CTIIT9STOP )CTIIT9


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*2a#$le : *#$loyee*2a#$le : *#$loyee

Millitech inter"ie'ed a $otential technicianMillitech inter"ie'ed a $otential technicianin March GHH. e ran a DPS, no #atchingin March GHH. e ran a DPS, no #atchingrecords.records.

Millitech hired this technician in July GHH.Millitech hired this technician in July GHH.

e ran a DPS and at this ti#e 'e had oure ran a DPS and at this ti#e 'e had our3rst direct hit on a $erson.3rst direct hit on a $erson. The alert 'as or a %1D %ousing and The alert 'as or a %1D %ousing and

1rban De"elo$#ent o!ense.1rban De"elo$#ent o!ense. e ased the e#$loyee about this 3ndinge ased the e#$loyee about this 3nding

and he ad#itted that he and his a#ily hadand he ad#itted that he and his a#ily hadbeen indicted or a %1D cri#e and thatbeen indicted or a %1D cri#e and thatthey 'ere 'aiting or the trial.they 'ere 'aiting or the trial.


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*2a#$le : *#$loyee*2a#$le : *#$loyee

cont0dcont0d Our President, %(, Finance Director andOur President, %(, Finance Director and#ysel called our legal grou$ and taled#ysel called our legal grou$ and taledabout this to$ic and ho' to $roceed.about this to$ic and ho' to $roceed.

Our decision 'as based on his -obOur decision 'as based on his -obdescri$tion


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*2a#$le & isitor*2a#$le & isitor ?eorge . Bush co#es to "isit and 'ants to?eorge . Bush co#es to "isit and 'ants to

$artner 'ith us on a deense (FP 'e are 'oring$artner 'ith us on a deense (FP 'e are 'oringon


19/20

*2a#$le & Su$$lier*2a#$le & Su$$lier Bharat *lectronics +td & IndiaBharat *lectronics +td & India

hen you loo u$ this co#$any you gethen you loo u$ this co#$any you geta country code alert.a country code alert.

In this e2a#$le India co#$anies areIn this e2a#$le India co#$anies areon a 'atch list or ato#ic energyon a 'atch list or ato#ic energynues $roducts.nues $roducts.

I Millitech 'as selling the#I Millitech 'as selling the#co#$onents that 'ould all into thisco#$onents that 'ould all into thiscategory 'e 'ould sto$ the acti"itycategory 'e 'ould sto$ the acti"ityor a$$ly or a license.or a$$ly or a license.


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7uestions87uestions8

Cindy PeetersCindy Peeters

c$eetersL#illitech.co#c$eetersL#illitech.co#

cindy peeters dps presentation 111004

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