Elements of an Effective Export Enforcement System Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies WA Practical Workshop, June 27-28, 2016

A Specialized Field Export Control Investigations are complex by nature International in scope Often involve complex, cutting edge technology or specialty goods and services Exports can move fast

The Toolkit Export Control Investigations require specialized knowledge Export laws, regulations, and related criminal and administrative codes Transportation and logistics procedures Trade routes and markets Proliferation threats and actors Commodities and technology of significant concern

Export Control is a Contact Sport Investigators should have a good rolodex Contacts in local and international law enforcement Licensing and policy officials Technical reach-back Industry contacts Port, airport, road and railway personnel

Proactive Enforcement Outreach is critical to success Imparts knowledge to participants in the process Keeps honest companies out of trouble Dishonest companies are now informed (mens rea) Provides the community with a point of contact for questions Gives the investigator a glimpse into the process Learn the way companies do legitimate business Note potential red flags for compliance issues

The First Rule of Criminal Investigations “If they’re doing something wrong, they’re probably doing something else wrong, too!” Known or suspected violators in export related industries or sensitive technologies Freight forwarders involved in fraudulent transactions, such as redelivery of stolen goods or facilitating credit card fraud Theft of sensitive goods not of use to the average criminal “Trouble magnets”

Special Agent – Office of Export Enforcement Questions? Donald Pearce Special Agent – Office of Export Enforcement donald.pearce@bis.doc.gov +1 202 482 7479