Federal Sanctions, Debarments & Excluded Parties


ESR offers three global sanction and watch list options that are recommended for any company that has a federal, state, or contractual mandate to check these foreign databases.

 

 

Employment Screening Resources (ESR) provides a wide range of sanction and global watch list searches that span the globe appropriate for any organization. Industry-specific datasets are available for the healthcare and financial services sectors. Ongoing monitoring is available for any of ESR’s sanction and watch list searches.

Financial Institution Sanctions Search (FISS)

Recommended for any company that has a federal, state or contractual mandate to check any of the databases below.

  • Financial Industry Regulatory Authority (FINRA)
  • Board of Governors of the Federal Reserve System (FRB)
  • Federal Deposit Insurance Corporation (FDIC)
  • National Credit Union Administration (NCUA)
  • Office of the Comptroller of the Currency (OCC)
  • Office of Thrift Supervision (OTS)
  • Securities and Exchange Commission (SEC) Database
  • Investment Adviser Registration Depository (IARD®) U.S. Department of the Treasury Consolidated List

U.S. Government Excluded Parties and Sanctions Searches

Recommended for any company doing business with the federal government, or that has a federal, state, or contractual mandate to check the System for Award Management (SAM) as well as those wishing to check the Treasury Department Office of Foreign Assets Control (OFAC) database of those involved in or supporting terrorism and/or narcotics trafficking.

  • Office of Inspector General (OIG)/General Service Administration (GSA) - The OIG was established by the Inspector General Act of 1978 (Public Law 95-452) as an independent unit responsible for promoting economy, efficiency, and effectiveness and detecting and preventing fraud, waste, and mismanagement in GSA programs and operations.
  • Office of Foreign Assets Control (OFAC) Specially Designated Nationals List (SDN) - Individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." U.S. persons are generally prohibited from dealing with them.
  • Department of State/Bureau of International Security and Non-proliferation Sanctions - Parties that have been sanctioned under various federal statutes related to nonproliferation.
  • Department of State / Directorate of Defense Trade Controls AECA Debarred List – Entities and individuals prohibited from participating directly or indirectly in the export of defense articles, including technical data and defense services. Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to “statutory debarment” or persons established to have violated the AECA in an administrative proceeding and subject to “administrative debarment.”
  • Department of Commerce / Bureau of Industry and Security (BIS) - "Denied Persons List" are individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited. "Unverified List" are end-users who BIS has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction. An "Entity List" are parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.
  • System for Award Management (SAM) Federal Excluded Parties System - The System for Award Management (SAM) is the official U.S. Government database that consolidates excluded parties and sanctions databases from the Excluded Parties Listing System (EPLS), Central Contractor Registration (CCR/FedReg), and Online Representations and Certifications Application (ORCA). For a complete list of contributing federal agencies, contact ESR.
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Medical Sanctions and Debarments

ESR checks Medical Sanctions through a bulk check of Medicaid disbarments that examines the Excluded Parties List System (EPLS) a component of the System for Awards Management (SAM) and the applicable state Medicaid sanctions list, done in large bulk for monthly, quarterly or annual reviews to ensure compliance with all applicable federal and state laws. The Medical Sanctions check is a deep drill down into a large number of names, aimed at limiting the number of potential hits that must be researched further by reviewing all possible identifiers.

  • National Practitioners Data Bank (NPDB) - The NPDB is a confidential information clearinghouse created by Congress to improve health care quality, protect the public, and reduce health care fraud and abuse in the U.S.
  • U.S. Food and Drug Administration (FDA) Debarment List (Drug Product Applications) - A public list of firms or persons debarred pursuant to sections 306(a), (b)(1) and (b)(2) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 335(a), (b)(1), and (b)(2)) as published in the FEDERAL REGISTER (FR).
  • Fraud and Abuse Control Information Systems (FACIS) / U.S. Healthcare Sanctions Search (FACIS 1m) Basic Level - This search is the minimum recommendation for any healthcare provider that participates in Medicare and/or Medicaid federal and state programs. All excellent due diligence for non-participating healthcare providers. ESR’s basic search option includes federal level data and is generally considered to be the baseline search for exclusions screening as outlined by the Department of Health and Human Services (DHHS) – Office of Inspector General (OIG) Guidance, DHHS – Centers for Medicare & Medicaid Services (CMS) Guidance to the State Medicaid Directors, and under The Patient Protection and Affordable Care Act (PPACA) of 2010.
  • FACIS / U.S. Healthcare Sanctions Search (FACIS 3) Enhanced Level - ESR’s Enhanced Healthcare Sanctions option includes the data sources included in the Basic Level as well as all state disciplinary findings from every publishing jurisdiction in the United States from all publishing disciplinary and licensing boards for all published professions within those jurisdictions. This is the most comprehensive search available in the United States and is considered the “Gold Standard” for sanction screening. This option includes over 3,000 sources.

Contact ESR for more information.

 

 

 

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