Sanctioned Party List and Embargo Check with SAP GTS 

Purpose

With this process you can use the connection to the component SAP Global Trade Services (SAP GTS), in order to check incoming and outgoing payments in Financial Accounting (FI) against sanctioned party list screening and embargo lists. Depending on the result of the check, you can prevent the payment transaction if necessary.

If you have activated the sanction list screening and embargo check in FI, then a check is made of the following transactions:

●      Payment creation in automatic processes

○       Payment program for customer/vendor items

○       Payment program for payment requests

●      Payment creation in manual processes

○       Proposal processing

○       Creating a payment with check printing

The check result is fully documented in SAP GTS, and can be analyzed there if problems occur.

For additional information on the component SAP Global Trade Services (SAP GTS) see the SAP library for SAP Global Trade Services (SAP GTS), for example, under SAP Compliance Management → Sanctioned Party List Screening.

Prerequisites

You must meet the following prerequisites if you want to use sanction party list screening and the embargo check:

●      You are using the component SAP Global Trade Services (SAP GTS) with at least Release 7.1.

●      You have connected the FI system to the SAP GTS system. In Customizing of SAP GTS system, you can find the appropriate settings under SAP Global Trade Services → System Communication → System Connection to Feeder System.

●      In Customizing of the SAP GTS system, you have made the settings required for SAP GTS.

For the FI connection, process-specific settings are necessary in the following areas:

○       SAP Global Trade Services → General Settings

○       SAP Global Trade Services → SAP Compliance Management → General Settings

○       SAP Global Trade Services → SAP Compliance Management → "Embargo Check" Service

○       SAP Global Trade Services → SAP Compliance Management → "Sanctioned Party List Screening" Service

●      You have carried out the initial transfer of master data from the FI system to the SAP GTS system. This involves the master data from the vendors, customers and banks areas.

●      You have made sure that all master data changes from your FI system are consistently replicated in the SAP GTS system.

The following special feature applies to bank master data: changes are not automatically transferred, you have to execute report /SAPSLL/BANKMAS_DISTRIBUTE_R3 (Initial Transfer Banks to SAP GTS) that you also use for the initial transfer.

You can find additional information on master data transfer in the following places:

SAP Library for SAP Global Trade Services (SAP GTS) under SAP Compliance Management → Master Data for SAP Compliance Management

Configuration Guide for SAP Compliance Management on SAP Service Marketplace by visiting service.sap.com/swdc→ Downloads → SAP Installations and Upgrades → Entry by Application Group → SAP Application Components → SAP GRC Global Trade Services → SAP GTS <Release> → Installation and Upgrade.

●      Before you activate the check for FI, you have made a check of the sizing of your SAP GTS system. For more information, see Quick Sizer.

●      SAP advises you to carry out appropriate tests before you activate the check for FI, thereby ensuring that your automatic payment processes continue to be performed on time.

●      In Customizing the FI system you have activated the sanctioned party list screening and embargo check for Financial Accounting (FI). To do this, choose one of the following IMG activities:

○       Financial Accounting → Financial Accounting Global Settings →Check in SAP GTS for FI → Activate Check in SAP GTS for FI

○       Financial Accounting (New) → Financial Accounting Global Settings (New) →Check in SAP GTS for FI → Activate Check in SAP GTS for FI

Process Flow

Sanctioned Party List Screening

The system uses the following data when it makes the sanctioned partly list screening when payment is made:

●      Customer master data

●      Vendor master data

●      Partner bank master data

●      Alternative payee/payer

●      Individual payment recipient in the document

●      Note to payee

●      Account holder

Individual payment recipient, note to payee and account holder are interpreted in SAP GTS as an address.

Embargo Check

For a complete embargo check, the system uses the country of the payment recipient/payer, and the country of the partner bank (if available).

For a partial embargo check, the system uses the direction of the cash flow, as follows:

●      Cash flow for incoming payments:

○       From the country of the payer to the country of the company code involved

○       From the country of the payer to the country of the house bank

○       From the country of the partner bank (if available) to the country of the company code involved

○       From the country of the partner bank (if available) to the country of the house bank

●      Cash flow for outgoing payments:

○       From the country of the company code involved to the country of the payment recipient

○       From the country company code involved to the country of the of the partner bank (if available)

○       From the country of the house bank to the country of the payment recipient

○       From the country of the house bank to the country of the partner bank (if available)

Termination of Checks

Where the connection to SAP GTS is not available when you create a payment, or the check cannot be made due to technical problems in SAP GTS, you have two options:

●      You use the standard setting that leads to the termination of the payment process. This applies both to automatic and manual payment processes.

●      You change this standard setting, and allow the payment process to continue.

                            a.      In Customizing, you choose Financial Accounting (New) → Financial Accounting Global Settings (New) → Tools → Change Message Control

                            b.      You change the settings for the following message numbers in work area FIPAY_GTS:

■       001 (Automatic process)

■       002 (Manual creation of a payment with check printing)

■       003 (Payment proposal processing)

With this second option, you have to schedule program Subsequent Check Made in SAP GTS for FI (RFBREAKDOWNGTS) regularly, in order to document and later complete terminated checks. You can find this program in the function Automatic Payment Transactions: Status. Choose Edit → Payment  → Check in SAP GTS → Payment → Carry out Subsequently.

For more information, see the program documentation.

It may make sense to have settings that differ from the standard system, for example, for creating payments with check printing. You can grant a certain user authorization to create checks even if the connection to the SAP GTS system is not available, or the check is not possible due to other technical problems.

Result

Payment creation in automatic processes

The check result is displayed in the payment run log. If the check in SAP GTS is unsuccessful, the system does not make the payments. The system shows the bill items concerned both in proposal processing and in the Exception List as an exception, and provides them with the following item indicators:

●      Indicator 82: Item locked due to check result in SAP GTS

●      Indicator 83: Item locked due to check result of a different item in this payment

If you would like to release an item despite this result, this is only possible once you have made a change in SAP GTS or have release this item there direct.

Payment creation in manual processes

If, when creating a payment with check printing, the check in SAP GTS is not successful, the end user is informed that the check cannot be created due to the check result in SAP GTS.

If, in proposal processing, you make a change for which the check in SAP GTS is not successful, you are informed that the change cannot be saved due to the check result in SAP GTS.