Red Flags

Red Flags

You’ve screened your customer, gotten licenses, and are ready to ship. But something still doesn’t seem right. There’s a feeling … an instinct … that’s prevented you from giving the green light.

Knowing your customers is one of the basic elements of compliance with export compliance laws. It’s important to review even minor changes to routine transactions with great care. Even the smallest detail can affect license requirements and exception applicability.

• Has your customer suddenly ordered a large quantity of controlled material that is outside their scope of business?
• Has your customer suddenly changed shipping methods or shipping addresses to an obscure location?
• Are they suddenly reluctant to disclose ultimate end use or destination?

All of these questions warrant further investigation. It’s always prudent to not only review each customer but also each transaction. The risk of inadvertent violations is reduced If you have policies and procedures in place that are consistently followed.

What’s more, you have a duty to investigate these red flags. Keep an open dialogue — do not instruct staff to remain quiet if they are unsure. Obtain all the requisite information to make an informed decision, which may include not completing the transaction or report red flags to the federal government and letting them investigate. Here is a link to the Bureau of Industry Standards, which provides examples of red flags and a reporting hotline.

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