Whose responsibility is it to screen for Denied Parties?

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has ruled that under the US Export Administration Regulations (EAR)​ ”all entities involved in a transaction” are responsible for complying with the EAR.​

Source: §744.11 and §744.16 of the EAR (effective August 7th 2020)

Failure to show proper due diligence has been undertaken can result in large fines for those involved.