Practical Guide to SAP GTS Part 1: SPL Screening and Compliance Management

2.1   Introduction

Everyone understands what a country embargo is; in other words, you may not deal with that country. For example, US companies cannot do business with North Korean companies. However, it is not as well known that government agencies more often embargo individuals and entities than they do countries. For example, the US Department of the Treasury lists entities in certain countries, such as Libya, that it considers a danger to the national interests of the United States. As a result, a US company may not sell to any of the listed companies or individuals. The lists of forbidden or restricted parties are called Sanctioned Party Lists (SPL).

SPL lists are commonly thought of an “export” issue, and most companies understand they must ensure they never export to a listed entity. However, these lists can apply to imports as well as domestic activity. Buying from or selling to a person in your own country could violate certain SPL rules; for example, there are US entities on many of the lists.

It is critical that your business protects itself from liability and screens all of its business partners against the published lists. To do so, a system must be set up that checks business partners (BP) as soon as they are created or edited and checks the partners within documents. Any time the system thinks that it has found a match, it will block the partner or document from use until it is reviewed by an authorized user. This user will decide on the block, i.e., is it really a match, or just a close match? If it is simply a close match, they can release the partner/document. If it is a real match, it will remain blocked.

In the next section, we will review the suggested settings, best practices, and user tips for SAP GTS SPL functionality. It is not intended to be exhaustive but rather covers the most commonly used areas of the software, as well as those most likely to cause confusion.

Before we begin, we would like to explain the high-level operation of SAP GTS SPL. To illustrate this, we will look at three simple process flows, including:

• How an SPL match is determined.
• How a business partner block is determined and managed.
• How an order block is determined and managed.

Figure 2.1, Figure 2.2 and Figure 2.3 display these processes in the form of a flow chart. These simple flows are not meant to capture all SAP GTS functionality but rather to provide a high-level overview of its three core competencies: determining a match, blocking a partner that matches, and blocking a document containing a matched partner. For example, there are many more settings available to fine-tune the match logic than what is shown. By reviewing this diagram, you will better be able to understand where the other features fit in and how they affect the outcome of checks.

Let’s look at a couple of key terms. When a user reviews a match, they must decide if they are looking at a true positive or a false positive. A true positive is an actual match, and the business partner is the SPL entity. A false positive means the system found that the two were close enough to warrant a block, but upon review, it has been determined that the match is not real.

Figure 2.1: SPL Match determination logic

Figure 2.2: SPL Business partner screening flow

Figure 2.3: Document blocking

This chapter delves into each of these areas in more depth, as well as covering areas not shown in these diagrams. Lastly, it wraps up with a general discussion on SPL compliance and tips for meeting the expected compliance standard.