Know Your Sanctions Lists (Beyond the CSL) – Chemical Weapons Convention Regulations (CWCR) Violations 

Beyond the Consolidated Screening List, ECScreening provides data from a growing number of official U.S. and foreign government sanctions lists and other sources to bring useful information to subscribers. 

One of these lists, from the Department of Commerce’s Bureau of Industry and Security (BIS), is published Chemical Weapons Convention Regulations (CWCR) Violations.  Similar to the list of BIS Export Violations, BIS publishes the names and case information for individuals or entities determined to have committed violations of the Chemical Weapons Convention Regulations, which implement the Chemical Weapons Convention (CWC).

Currently, there is only one case listed, CWCR-1 for Geomet Technologies, L.LC. dated March 24, 2011), which includes a link to the Department of State order requested by the Department of Commerce, related to Geomet’s CWCR reporting and recordkeeping violations.  This order acknowledges a settlement made between Geomet and BIS, a fine paid to the Department of State, and the publication of the order.

ECScreening continues to monitor for new additions to this list.

Settlement agreements serve as important background information for due diligence, highlighting weak compliance areas that have already been identified.    If your screening process turns up a CWCR violation, it is important to review the published documents to determine whether the violation directly impacts a proposed transaction or is merely informative.  They may even suggest the potential for a company’s improved compliance program.