Hello,
We want to make sure that we flag any securities/companies that are restricted by the recent Executive Order which is the following Source:
abbreviation: US-EO13959,
creationDate:2020-11-21,
name: USA - US-EO13959 - Chinese Military Companies,
region Of Authority: USA,
description: This gives details of individuals, companies and vessels with whom national or supranational bodies have decreed firms should not have financial dealings. Dealings with these designated persons or entities can lead to large fines, jail sentences and increased regulatory oversight owing to perceived failures in systems of internal control.,
type: Sanctions
However, when we make the request: "SEQ-5c: Get a World-Check profile" with some of the Chinese Military Companies of the executive order here:
https://media.defense.gov/2020/Aug/28/2002486689/-1/-1/1/LINK_1_1237_TRANCHE-23_QUALIFYING_ENTITIES.PDF
For example when we test for the worldcheck-profile-id: e_tr_wco_1341134 which is restricted by the executive order, we don't get any actions or details with detail type SANCTION. The only way we could identify that this company is restricted by the executive order is by this element in the details list:
{
"detailType": "REPORTS",
"text": " Aug 2020 - entity operating directly or indirectly in the US. Determined by US Pentagon to be owned/controlled by the People's Liberation Army (PLA), and engaged in commercial/manufacturing/production/export activities. The US President is authorised to impose sanctions on such entities pursuant to the National Defence Authorisation Act, 1999. Nov 2020 - named on Executive Order 13959 issued on 12 November 2020 related to Chinese military companies effective 11 January 2021. Dec 2020 - OFAC publishes Communist Chinese Military Companies Frequently Asked Questions related to EO 13959.",
"title": "REPORTS"
}
However for our algorithm to pick that restriction, it means it should look not just for SANCTION actions but also for REPORTS detail type.
We are worried though that this will result to a lot of false positives when checking for other companies unrelated to this executive order.
Could you please make it more clear of why we get only a REPORTS declaration and no SACTION for this? How could we make sure that we identify companies restricted by this executive order without creating a lot of false positives?
Thanks a lot! Looking forward to your response.
