All exporters, sellers and U.S. financial institutions participating in the GSM-102 and/or FGP programs must register in the System for Awards Management (SAM), in accordance with U.S. Government regulations found at 2 CFR Part 25. SAM (www.sam.gov) is the official repository for standard information about applicants and award recipients under U.S. government programs. In addition registering in SAM, exporters, sellers and U.S. financial institutions, unless exempted from these requirements under 2 CFR 25.110, must review and update their information annually (or more frequently, if needed) in the SAM database to ensure it is current, accurate and complete.
2 CFR Part 25 also requires that Federal agencies establish a unique entity identifier for all applicants for and recipients of federal financial assistance, including loan guarantees. The acceptable unique identifier for the GSM-102 and FGP programs is the Data Universal Numbering System (DUNS) number issued by Dun & Bradstreet. All U.S. exporters, sellers and U.S. financial institutions participating in the GSM-102 and Facility Guarantee Programs (FGP) are already required by those program regulations (7 CFR Part 1493) to have a DUNS number.
As of May 1, 2017, exporters and sellers will be unable to receive payment guarantees, and U.S. financial institutions will be unable to take assignment of guarantees, if not in compliance with the requirements of 2 CFR Part 25.