Purpose: Use this job aid as a checklist for identifying red flags that may indicate the potential for EAR violations.
The following red flags should alert you to the possibility of an EAR violation:
- the customer's name or address is similar to one of the parties found on the BIS's list of denied persons
- the customer or purchasing agent is reluctant to offer information about the end use of the item
- 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 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 customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing
- the customer has little or no business background
- 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
- 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
- when questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, export, or re-export
Course: US Export Controls
Topic: Compliance with the EAR
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