Screening export shipments has become routine for most companies involved in international trade. Export software packages can perform this task or it can be manual; using the Consolidated Screening List https://www.trade.gov/consolidated-screening-list or individual lists. No one wants to do business with the bad guys. However, the routine nature of export screening makes it likely that upper level management is not involved in the process.

We always emphasize the role of C- level executives in compliance. Here is where C-level leadership is important:

SUPPLEMENT NO. 3 TO PART 732 – BIS’s “KNOW YOUR CUSTOMER” GUIDANCE AND RED FLAGS

(3) Do not self-blind. Do not cut off the flow
of information that comes to your firm in the
normal course of business. For example, do not
instruct the sales force to tell potential customers
to refrain from discussing the actual end-use, end user, and ultimate country of destination for the
product your firm is seeking to sell. Do not put
on blinders that prevent the learning of relevant
information. An affirmative policy of steps to
avoid “bad” information would not insulate a
company from liability, and it would usually be
considered an aggravating factor in an
enforcement proceeding.

For help with exports or developing an ECP (Export Compliance Program) contact mitch@adhoclogistics.com