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Export controls' red flags

Thursday, January 19, 2012 - 01:00

User-related fact patterns
• The customer appears on one of the blocked-persons lists. Links to the current lists can be found at www.bis.doc.gov/ComplianceAndEnforcement/ListsToCheck.htm.
• The customer or ultimate end-user is unknown.
• Financial information about the customer is unavailable.
• The customer is willing to pay well in excess of market value for the shipment.
• When questioned, the buyer is evasive about whether the purchased product is for domestic use, for export, or for re-export.
• The purchaser is reluctant to provide information on the end-use or end-user of the product.
• The customer appears unfamiliar with the product, its application, support equipment, or performance.
• The customer orders products or options that do not correspond with its line of business.
• The customer has little or no business background.
• Firms or individuals from foreign countries other than the country of the stated end-user place the order.
• The customer declines normal service, training, or installation.
• The product’s capabilities do not fit the buyer’s line of business, such as an order for sophisticated computers for a small bakery.
• The customer’s order seems inappropriate, such as an order for a replacement part for an item that the customer never ordered.
• The customer is willing to pay cash for a very expensive item when the terms of sale normally would call for financing.
• The customer is unfamiliar with the product’s performance characteristics but still wants the product.
• Routine installation, training, or maintenance services are declined by the customer.

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