Kelly,
Below are the lists that Navigator searches.
Note: SDN stands for specially designated national. The Office of Foreign Asset Control (OFAC) places individuals and entities on this list for national security, foreign policy, and sanctions policy objectives.
As to PEPs searches, I know that we do these for new clients, from all offices, and recently for pitches.
I do not believe that we are doing any PEPs searches for existing clients.
I am copying Karen to ensure that I have provided the correct answers.
From: Patterson, Julia <jpatterson@hunton.com>
Sent: Monday, May 14, 2018 1:12 PM
To: Hayes, Ed <ehayes@hunton.com>
Cc: Lebo, Karen <klebo@hunton.com>; Bear, Jennifer <JBear@hunton.com>; Niemela, Charlene <cniemela@hunton.com>
Subject: RE: Navigator's (a/k/a Intapp) Restricted Watchlists (e.g., OFAC, DPL, etc.)
These are the lists we are currently loading into Navigator.
| SDN | Specially Designated Nationals (SDN) - Treasury Department |
| FSE | Foreign Sanctions Evaders (FSE) - Treasury Department |
| PLC | Palestinian Legislative Council List (PLC) - Treasury Department |
| SSI | Sectoral Sanctions Identifications List (SSI) - Treasury Department |
| 561 | Part 561 List (561) - Treasury Department |
| OFSI-STL-I | Canada Office of the Superintendent of Financial Institutions - Sanctions Trade List for Individuals |
| OFSI-STL-E | Canada Office of the Superintendent of Financial Institutions - Sanctions Trade List for Entities |
| UK-CLT | United Kingdom - Her Majesty’s Treasury - Financial Sanctions List |
| DPL | Denied Persons List (DPL) - Bureau of Industry and Security |
| EL | Entity List (EL) - Bureau of Industry and Security |
| DTC | ITAR Debarred (DTC) - State Department |
| ISN | Nonproliferation Sanctions (ISN) - State Department |
| UVL | Unverified List (UVL) - Bureau of Industry and Security |
| 13599 | List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 (13599) - Treasury Department |
From: Faglioni, Kelly <kfaglioni@hunton.com>
Sent: Tuesday, October 5, 2021 9:51 AM
To: Hayes, Ed <ehayes@hunton.com>
Cc: Novy, Debbie <DNovy@huntonak.com>
Subject: Sanctions lists checking -- just confirming
I need to check some facts about when OFAC lists are searched – I think I understood that they are incorporated into the Intapp conflicts searching, so technically every name that is searched is passed through the OFAC list and would be reported out if there was a hit (whether new or existing client, adverse party, or non-adverse). Can you confirm or tell me who I should ask to confirm?
With respect to the PEP searches, I understand that we are doing them for every new client, correct? Is it also correct that we are NOT doing PEP reports for existing clients absent a special request (or perhaps an AML compliance requirement, such as first work out of London office)? Again, let me know if you can answer or if I should grab someone else in BIC to confirm.
We can talk or if you prefer to email today, that is OK too.
Debbie, I will circle back to you with input on the questions when I confirm these details.
Thanks,
Kelly
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| Kelly Faglioni Partner and Deputy General Counsel
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