Before the review
Record the scope of the review
A useful review records the parties checked, the ownership information available and the proposed goods, services and payment arrangements. It should identify information gaps and the date of the assessment. Changes to a party, owner, bank or transaction may require further review.
Scope of the review
Information needed for the review
A list search does not cover every restriction. The review also needs information on ownership, the activity and how the transaction will be performed.
Names
The direct parties and connected persons.
Ownership and control
Direct, indirect and practical control.
Subject matter
Goods, services, technology, destination and use.
Payment
Banks, intermediaries, currency and documents.
Contract
Evidence, notice and a lawful response to restrictions.