To make sure we don't inadvertently do business with criminals, terrorists, or sanctioned parties, we screen known end users and other parties to our transactions against various lists maintained by governments. You should make sure companies are screened:
the first time we do business with them
prior to order acceptance or placement
if there is a major change in ownership, business line, or structure
at other designated points in the transaction, as required by our procedures
In many cases, it will make sense to screen every person involved in a transaction. Work with the trade compliance team if you have questions.