Export control and economic sanction requirements have been around for years, but now are taking on increasing prominence in the wake of record-setting fines. It is now more important that ever to be aware of export controls and economic sanctions red flags. Priming employees to be alert to the following red flags is an important bulwark against export controls and economic sanctions missteps.
Shipment-related fact patterns
• The final consignee is a trading company, freight forwarder, export company or other entity with no apparent connection to the purchaser.
• Delivery dates are vague or deliveries are planned for out-of-the-way destinations.
• A freight-forwarding firm is listed as the product’s final destination.
• The shipping route is abnormal for the product and destination.
• Packaging is inconsistent with the stated method of shipment or destination.
Order-Related Fact Patterns
• The customer volunteers or is willing to pay cash for a high-value order, rather than using a standard method of payment.
• The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.
• The end-use information provided is incompatible with the customary purpose for which the product is designed.
• “Fragile” or other special markings on the package are inconsistent with the commodity described.
• The product is inappropriately or unprofessionally packaged (e.g., a freight forwarder receives a package that is unusually packaged).