- within Insolvency/Bankruptcy/Re-Structuring, Media, Telecoms, IT, Entertainment and Technology topic(s)
In the National Association of Credit Management'sBusiness Credit
Magazine, Ola Craft outlines how credit
professionals can properly navigate the Bureau of Industry and
Security's (BIS) Affiliates Rule, which requires businesses to
conduct more extensive due diligence through its restrictions on
entities that are at least 50 percent owned by parties listed on
the Entity List, Military End-User List, or certain Specially
Designed Nationals and Blocked Persons lists. The four-step
compliance guide for creditors considers ownership mapping and due
diligence; enhanced KYC and escalation; compliance rules and
transaction review; and training and vendor management.
Craft notes the possibility of adapting current practices to the
rule as opposed to establishing new procedures. She says,
"There may be processes and ownership mapping already in place
due to compliance with OFAC regulations, but those can be adapted
in accordance with new regulations." She also advises
creditors to apply "the most restrictive standard" to
transactions to minimize risk.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
