U.S. exporters can be held criminally responsible for export control violations stemming from routed export transactions, according to U.S. government officials at a recent export enforcement panel in Washington D.C.
When a foreign entity controls the transportation of U.S. exported goods, the U.S. government considers the shipment to be a routed export transaction.
Exporters engaging in these types of transactions need to also keep in mind that they are on the hook if a violation occurs, such as a licensing or classification error. As one State Department official pointed out: “You’re the one with all the records. You’re the one responsible.”