Updated Export Red Flag Checklist

August 26, 2013
By Michelle Kelley

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We’ve updated this checklist to include the new 600 series Export Control Classification Numbers (ECCN). Attend our upcoming seminar, Building Your Export Compliance Program, to receive a program-ready, limited edition of this form.

When any of the following Red Flag Indicators have been identified and follow-up inquiries have not satisfactorily resolved doubts, you should not proceed with the export in question. See the Bureau of Industry & Security’s “Know Your Customer” Guidance at: www.bis.doc.gov.

Is/does your customer…?

  • reluctant to offer info about product’s end-use/end-user
  • have little or no business background
  • want to pay cash for an expensive item that normally calls for financing
  • unfamiliar with how product works but still wants it
  • decline routine installation, training, or maintenance services
  • evasive/unclear about domestic use/export/re-export
  • use only a PO Box address
  • have facilities that appear inappropriate for the product
  • known to have/suspected of unauthorized dealings with embargoed countries
  • order large quantities of a new 600 series ECCN for an end item to a country that is known to have few to none of the end item
  • indicate the potential for a 600 series ECCN to be reexported to a destination listed in Country Group D:5 (15 CFR 740 Sup. 1)

Is/does your product…?

  • have capabilities that don’t fit buyer’s line of business
  • incompatible with the technical level of destination country
  • suit no legitimate need of the customer

Is/does your delivery…?

  • have vague delivery dates
  • planned for an out-of-the way destination
  • list final destination as a freight forwarder’s address
  • have an abnormal shipping route for the product/destination
  • have packaging inconsistent with the method of shipping or destination

 

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