Working with entities that have been sanctioned by government agencies or law enforcement can make it more difficult to do business. The U.S. Office of the Inspector General (OIG) issued a notice listing factors it will consider in exercising its discretion to exclude owners, officers, or managing employees of entities that have been excluded from participation in federal health care programs or convicted of certain offenses. The statute allows the OIG to exclude an individual from participation in Federal health care programs simply for being an officer or managing employee of a sanctioned entity. The OIG may also exclude an owner of such an entity if he or she knew or should have known about the misconduct leading to the sanctions, as well as a managing employee or officer. These decisions cannot be appealed, and their presumption is generally in favor of exclusion and sanctions.

There are four broad categories the OIG takes into account when considering sanctions:

• The circumstances and seriousness of the offense
• The individual’s position in the sanctioned entity
• The individual’s actions in response to the misconduct (did they try to stop or mitigate its impact, and/or disclose it to the authorities?)
• The structure and history of the sanctioned entity (including previous sanctions, charges, or convictions)

Global Sanctions List

WorldCompliance aggregates information from the most important sanction lists around the world and groups them into one category called the Global Sanction List, which is comprised of individuals and companies of the highest risk rating.

Consolidated Sanction List

We have created something truly unique in the industry, by consolidating the information from all major sanction lists around the world while fully maintaining the integrity of the underlying data. As a result, a search for the most wanted man in India will result in a single match, despite his inclusion in all major sanction lists.

Covered lists include:

• Her Majesty Treasury List
• Bureau of Industry and Security
• Department of State
• EU Terrorism List
• FBI Top Ten Most Wanted
• Interpol Most Wanted
• ICE List (U.S. Immigrations and Customs Enforcement)
• Office of Foreign Assets Control (OFAC) Sanctions
• CBI List (The Central Bureau of Investigation)
• SDN & Blocked Entities
• SECO List
• Treasury PML List
• UN Consolidated List
• OCC Shell Bank List
• World Bank Debarred Parties List