- Why does the Shipwire Platform need to screen orders against the Restricted Parties List (RPL)?
As a U.S.-based company, we comply with U.S. government regulations prohibiting U.S. companies from doing business with persons or companies listed on the RPL.
- How does the RPL screening logic work?
The customer name on the order is checked against the RPL using industry standard compliance software and a score is created based on the potential match. Scores above a certain threshold will result in an RRL hold on the customer order(s).
- Why did an order go on RPL hold?
We have installed an industry standard export compliance software program within the Shipwire Platform to prevent sales to unauthorized parties, as identified by the U.S. government. Any non-domestic U.S. to non-domestic U.S. orders (excluding Canada) will go through this review process (usually takes less than a few hours, unless escalation is needed).
- When an order has a positive match from the RPL database, how soon will it be released?
The order will remain on hold until our compliance team has confirmed that none of the potential matching parties are on the RPL. Orders will be reviewed and released within 1 business day. If customer escalations are required, orders will be on hold until customers have confirmed.
- If my customer is not on the RPL, why was the order still put on RPL hold?
Our software identifies potential matches to a name on the RPL based on industry standard export compliance software program that determines a close match to a restricted party. Should there be a close match, the system will put the order on hold for further analysis.
- If a Ship To name is confirmed a match against the RPL, what do I tell my customer?
The U.S. government prohibits sales to any party listed on the Restricted Party List. As a U.S.-based company facilitating exports, Ingram Micro Commerce & Fulfillment Solutions cannot ship the order and it will be cancelled. You should communicate to your customer that shipping to Restricted Parties is a violation.
- I am shipping from EU to EU (or other non-U.S. to non-U.S. country). Why are my orders still subject to U.S. regulation?
Ingram Micro Commerce & Lifecycle Services, is a U.S.-based company working with customers around the world. As a U.S. company, it is Ingram Micro’s corporate and legal responsibility to comply with U.S. regulation and screen all transactions against the RPL. The United States government and its export regulations restrict or prohibit U.S. individuals and companies from exporting or providing services of any kind to any party contained in U.S. government export denial, debarment, and blocked persons lists. Failure to comply is a violation of U.S. law and can result in civil or criminal prosecution, as well as denial of exporting privileges. Restricted party lists (also called denied party lists) are lists of organizations, companies or individuals that various U.S. agencies—and other foreign governments—have identified as parties that one can’t do business with. In the United States, the primary restricted party lists are published by the Department of Commerce, Department of State, and Department of Treasury. However, several other agencies produce lists as well.
- Are there consequences if RPL isn’t done?
According to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), fines for export violations can reach up to $1 million per violation in criminal cases. Administrative cases can result in a penalty amounting to the greater of $250,000 or twice the value of the transaction. In addition, criminal violators may be sentenced to prison for up to 20 years, and administrative penalties may include denial of export privileges.
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