Managing Sanctions against Natural and Legal Persons

Objectives

After completing this lesson, you will be able to:

  • Describe the functioning of sanctioned party list screening in SAP GTS

Legal Background

The sanctions that are the subject of this lesson are directed against certain natural and legal persons included in lists of names, regardless of their whereabouts. As a rule, funds and economic resources owned, in the possession of or controlled by the listed persons will be frozen. It is usually prohibited to provide funds or economic resources to the listed persons.

Many sanctions against natural and legal persons implement UN Security Council resolutions.

Sanctioned Party List Entries as Master Data

In SAP GTS, name lists are composed of individual master records for each entry. A master record of this kind contains all the data (names, possibly addresses, nationalities, and identification card numbers) disclosed for a natural or legal person in the respective sanctioned party list. In the various check scenarios of this sanctioned party list screening, the system compares these master data with the relevant business partner's address data.

You can purchase full lists in XML format from data providers and upload them to your SAP GTS system. The system generates sanctioned party list master data from these XML files. However, you can also manually enter sanctioned party lists in the system, either in their entirety or in part. This allows you to create company-specific lists, for example. Authorities amend their sanctioned party lists at regular intervals and usually add entries to them. Data providers for SAP GTS supply their customers with the necessary updates.

You can create, change and display sanctioned party list entries using the Manage Sanctioned Party List Master app. To display entire lists, you can use the Display Sanctioned Parties app.

Sanctioned Party List Screening in the Processes

The main function of sanctioned party list screening in Compliance Management is to compare business partner addresses with sanctioned party list entities. If the system identifies a match between a business partner address and a sanctioned party list entity, it blocks the business partner in question. Replicas of feeder system documents that contain a blocked business partner are also blocked. Any documents that existed before the screening was run must be checked again.

The screening procedure in sales and purchasing processes are largely identical.

You can display business partners and documents blocked as a result of sanctioned party list screening and release them if required. To display, and if permitted, release blocked business partners, use the Manage Blocked Partners app. To display and release blocked documents, you can use the Manage Blocked Documents app.

If you want to exclude business partners from regular sanctioned party list screening, you can add them to the positive list, either from a list of screening results or by setting the Address is on the positive list indicator in the business partners’ master data (SAP GTS tab). Business partners can be added to the negative list if they are to be blocked although they do not appear on a sanctioned party list.

Screening Scenarios

Sanctioned party list screening of business partners and documents is carried out either synchronously or asynchronously depending on the Customizing settings.

In asynchronous screening, the SAP GTS system first determines the blocking status of the business partner when master data or documents are transferred. New business partners are always blocked as a precautionary measure. Manual changes to partner addresses in a feeder system document always result in a precautionary block of its replica in SAP GTS.

In synchronous screening, new and changed business partner addresses are compared with the sanctioned party list entities immediately after their transfer from the feeder system.

When feeder system documents are transferred, SAP GTS only checks the status of the business partners (blocked or not blocked). However, manual changes to partner addresses in a feeder system document result in an immediate address comparison with sanctioned party list entities in synchronous screening.

Screening Scenarios for Sanctioned Party List Screening

  • A scenarios (Asynchronous Screening): If sanctioned party list screening is to be run asynchronously, the A scenarios can be used to perform the screening online or in the background. Soft blocks are removed or, in cases where matches with a sanctioned party list entry are suspected, are replaced with hard blocks.

  • B scenarios (Periodic Screening): In scenario B1, all selected business partners are subject to sanctioned party list screening. In scenario B2, the system checks all documents for which the business partner addresses were changed in the feeder system document. B scenarios are also available for both online and background processing.

  • C scenarios (Screen Against Updated Sanctioned Party Lists): These scenarios are used when new sanctioned party lists or additions to existing sanctioned party lists have been uploaded. The system compares the business partner addresses only with the delta between the existing and new data set.

  • S scenarios (Simulation of Sanctioned Party List Screening): In these scenarios, you can simulate sanctioned party list screening. This means no blocks are set.

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