Time period of screening former employees or entities for exclusions

Question:

How long should we screen individuals or entities no longer affiliated with our organization?

Answer:

Following best practices for screening, Venops recommends screening all previous employees and vendors for one year following termination of employment or contracts. Reasons for this include:

  • Industry standardization for notifying previous employers/affiliates following exclusion activation does not exist.
  • Additional exclusions are activated monthly by the various exclusion and sanction authorities.
  • Names with a status of “clear” during previous rounds of screening are often found to match new exclusions, requiring another clearance investigation.