EXIM Convicted Parties List

Section 406

The following lists (Part 1 and Part 2) have been compiled together pursuant to the procedures implementing Section 406 of the Export-Import Bank Reauthorization Act of 2019, which is also referred to as the EXIM Convicted Parties List. Section 406 has been incorporated into the EXIM Bank Charter under Section 2(f) (12 USC 635(f)), and directs EXIM Bank to deny applications for transactions in which certain parties have been convicted for fraud or corruption in connection with EXIM transactions.             

Please note that many of the individuals and companies listed on the Part 1 and Part 2 lists below have separately been excluded from participating in Covered Transactions – which includes all EXIM transactions – pursuant to the Debarment Regulations (12 C.F.R. Part 413).  The Part 1 and Part 2 lists below do not in any way limit the exclusions put in place pursuant to the Debarment Regulations.  Those exclusions can be seen by putting the party’s name in the search of the Federal Government exclusions list found at https://sam.gov/search/.  Even if a party is not excluded from EXIM transactions by being on either the Part 1 or Part 2 lists below, that party may still be excluded pursuant to the Debarment Regulations.

In addition, parties that are delinquent on debt owed to the Federal Government are also prohibited from participating in Federal Government programs, including EXIM transactions.  Many parties that have been convicted in connection with EXIM matters are also ordered to pay criminal restitution to EXIM, but are delinquent on such debt, and therefore cannot participate in Federal Government programs.  This applies to parties that were convicted more than 5 years ago as well.

PART 1

EXIM GUARANTEES AND INSURANCE DO NOT APPLY TO ANY TRANSACTION IN WHICH ANY INDIVIDUAL OR COMPANY LISTED ON THIS PART 1 LIST IS A BUYER, BORROWER, END-USER, LENDER OR EXPORTER.

This Part 1 list is a list of individuals or companies that were convicted “in connection with an application made” in the preceding 5 years.  Pursuant to Section 406, EXIM may not support any transaction in which any individual or company on this Part 1 list is a borrower, end-user, lender or exporter. 

PART 2

Parties on this Part 2 list are not necessarily excluded from EXIM transactions.  HOWEVER, YOU MUST GET EXIM’S EXPRESS WRITTEN PERMISSION BEFORE PROCEEDING WITH AN EXIM-SUPPORTED TRANSACTION IN WHICH ANY INDIVIDUAL OR COMPANY LISTED ON THIS PART 2 LIST IS A BUYER, BORROWER, END-USER, LENDER OR EXPORTER.

This Part 2 list is a list of individuals or companies that were convicted within the preceding 5 years in any matter that has any connection to EXIM, and also includes companies known to be affiliated with such convicted parties.

The date of the individual’s or company’s conviction is set forth on the same line as the name of the individual or company, along with the names of companies known to be affiliated with the individual.