Diehards: RE: Sanctions lists checking -- just confirming

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