Restricted Party Access – Automation and Trade Compliance

How do you implement automation for restricted party screening for visitors and contractors that must be vetted before coming to your facility for either ITAR or EAR?

Facilities that deal with sensitive information such as research labs or manufacturers of technology for the Government or could be deemed a potential security risk if foreigners get access to these facilities’ sensitive data.

The Government imposes stringent trade compliance guidelines to follow. As a result, each visitor needs to be vetted before entering the building. Although coordinating all of this, it’s no easy task for any organization. Trade compliance professionals have their hands full in developing enforcing these regulations across the organization.

If any of these, regulations are breached, the organization is liable for significant fines and potential imprisonment. The MyLobby Visitor Management system streamlines and automates the whole process. The traditional paper trail process is time-consuming, difficult to maintain due to its complexity and not to mention, lots of paperwork. MyLobby Visitor Management system is a central platform that captures and stores all the data of your visitors.

First, we’re going to paint a picture of how most organizations today are grappling through the challenges brought on by restricted party screening, and then we’re going to outline how we can automate with the visitor management system  

The Proper term used in the Industry

There are multiple terms used, such as sanction list, restricted party screening or denied party screening. Oh, and Persona non-Grata, that last one is my embellishment to make this dry article a little bit more entertaining. Also, a few different compliance regulations, two common ones are: ITAR =  International Traffic in Arms Regulations is a United States regulatory regime to restrict and control the export of defense and military-related technologies to safeguard U.S. national security and further U.S. foreign policy objectives. EAR =  Export Administration Regulations  A set of regulations found at 15 C.F.R. § 730 et seq. They are administered by the Bureau of Industry and Security, which is part of the US Commerce Department. In general, the EAR governs whether a person may export a thing from the U.S., reexport the thing from a foreign country, or transfer a thing from one person to another in a foreign country. The EAR applies to physical things (sometimes referred to as “commodities”) as well as technology and software. Compliance professionals deal with the complexity of coordinating with the entire organization and managing visitor screening daily and it’s getting tricky. Their responsibility and roles consist of:

Phase I

Following procedures for the host (employee) that is inviting the visitor:

1. Complete and sign the Visitor Request Form.

2. Request a copy of the visitors’ Passport or other proof of residency translated into  English. (Required before entry is granted).

3. Provide a detailed outline of what areas the visitor would need access to, and which meeting rooms are requested.

4. Outline the nature of the meeting, such as if any technology is going to be shared or discussed.

5. Submit the completed form, proof of residency within a minimum of 48 hours before a visit to the trade compliance office.

6. During the meeting, remain in approved areas and follow to all boundaries during the visit.

7. The host is required to accompany the visitor at all times or make arrangements for an attendant during the visit. This commitment of the visit must include as much detail as possible to categorize it as either a vendor meeting or a sales presentation.

Furthermore, a brief description of the details of the meeting. No doubt the above steps are a heavy load, but that’s just the beginning.

Phase II

Trade Compliance Office (TCO) roles and responsibility consist of:

1. Screen or examine the denied party screening for the visitor and their employer.
2. Evaluate the access requested to display the technology request.
3. Inform, host of restrictions with their impending visit
4. Direct approved visit to front reception/security
5. Most importantly, keep a copy of the approved visitor form and any other related documents for five years.

The five steps seem pretty easy, right? Just imagine an organization with 600 people having a constant stream of visitors coming through the doors. Having to deal with someone who forgot their Passport or other government documents and has a critical meeting with people in the organization. Talk about pressure…. Trade Compliance professionals made up the term THANK GOD IT’S FRIDAY.

Phase III

Front desk Role and Responsibility:

1. When a visitor enters, they must sign in at the front desk.
2. The receptionist will ask the visitor to provide a Passport, Permanent Resident Card or other evidence of resident status in their home country and a photo ID. If there is no copy on file, the receptionist will send a copy to the Trade Compliance Officer.
3. Compare the documentation on the approved visitor form if it is the same; send notification of arrival to the TCO. If not, call TCO for further directives.
4. If prior approval was not granted, ask the host to complete the visitor form, photocopy passport or other proof of residency (photo ID is required) and send a notification to the TCO.
5. If the visitor information is different from the pre-approval or if the host has not completed the form, notify the TCO who will follow up.
6. Complete the Visitor Log.
7. Issue a Foreign Visitor Badge as required. Ask all visitors to wear the badge that is visible at all times while in the building.

Just seven simple steps; EASY AS PIE RIGHT? WRONG! The number of variables that can go wrong is overwhelming.  I like to compare the whole process kind a like commercial flying. You A slew of problems could arise you cannot control, such as; delayed flights, plane malfunction or my favorite, getting kicked off the plane, because of oversold seating, YEAH, THANKS UNITED AIRLINES! Managing restricted party screening makes airline flying look like fun. NOT!