In February 2025, the CAATSA 231(e) List was added to AEB's portfolio of restricted party lists. Should this list be relevant for your company, and you wish to include it into your AEB Compliance Screening software, the CAATSA 231(e) List can be licensed in addition to your already existing content.
What is the meaning of this restricted party list?
The list is based on the “Countering America's Adversaries Through Sanctions Act” (CAATSA). The law was passed by the US Congress in July 2017 and came into force on August 2, 2017. The CAATSA Section 231(e) List is published by the U.S. Department of State and consists of two parts:
- The first part “List Regarding the Defense Sector of the Government of the Russian Federation” contains entities that are part of, or operating for or on behalf of the defense sector of the Russian government.
- The second part “List Regarding the Intelligence Sector of the Government of the Russian Federation” includes individuals and entities that are part of, or operating for or on behalf of the intelligence sector of the Russian government.
The original list can be found at the following link: CAATSA Section 231(e) Defense and Intelligence Sectors of the Government of the Russian Federation - United States Department of State
It is important to emphasize that the CAATSA Section 231(e) list contains the so-called “Secondary Sanctions”. While only US persons fall within the scope of the “primary sanctions”, US laws with so-called “secondary sanctions” must be complied with by all companies worldwide from a US perspective.
On the basis of the CAATSA Section 231(e), OFAC has included entities named in the “CAATSA List” in various sanctions programs of the SDN List. The specific characteristics of the secondary sanctions can be found in the respective list entry in the SDN List.
Which companies should screen against the “CAATSA Section 231(e) List”?
Screening against the CAATSA Section 231(e) list is to be considered as a supplement to screening the SDN list and OFAC-CSL. Screening against the CAATSA Section 231(e) list is at the company’s discretion.
Do you need to license this list if you use third-party content in Compliance Screening?
If you screen your business partners against restricted party list content from providers such as Reguvis or Dow Jones in your AEB Compliance Screening application, the CAATSA Section 231(e) List may already be included in your content. In that case you do not need to license this list separately/additionally. For more information, please contact your content provider.
Efficient restricted party list screening – the “CAATSA Section 231(e) List” and more: How can AEB help?
The AEB Compliance Screening Module takes care of restricted party list screening against the CAATSA Section231(e) List and performs the screening automatically in the background – upon request also integrated into SAP®, Salesforce, Microsoft Dynamics 365, and other ERP and CRM systems. Please find an overview of AEB's available restricted party lists here.
- If you wish to include the CAATSA Section 231(e) List in your Compliance Screening, please request a non-binding quotation. Via the form, you can also contact a product expert.
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