End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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Presentation transcript:

End-Use Verification

Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department

U.S. Department of Commerce Bureau of Industry and Security (BIS) Bureau of Industry and Security (BIS) Export Control AttachesExport Control Attaches Sentinel TripsSentinel Trips Embassy ChecksEmbassy Checks

Export Control Attaches

Sentinel Trips Sentinel Trips Teams of two export control officialsTeams of two export control officials Travel to one or two countriesTravel to one or two countries Embassy Visits Embassy Visits Conducted by the Foreign Commercial ServiceConducted by the Foreign Commercial Service

Red Flags Party to the transaction has previous enforcement issues Party to the transaction has previous enforcement issues Party to the transaction is sanctioned by another government Party to the transaction is sanctioned by another government Party to the transaction has divisions or branches involved in prohibited uses or located in prohibited destinations Party to the transaction has divisions or branches involved in prohibited uses or located in prohibited destinations Party to the transaction has same or similar address to any of the above Party to the transaction has same or similar address to any of the above Consignee or End-use is located in a transshipment point Consignee or End-use is located in a transshipment point

Red Flags Unknown consignee on license application Unknown consignee on license application Sensitive Commodity Sensitive Commodity 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 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 industrial base of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no semiconductor industry The item ordered is incompatible with the industrial base of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no semiconductor industry

Conducting the End-Use Check Pre-License Checks (PLC) Pre-License Checks (PLC) Post Shipment Verifications (PSV) Post Shipment Verifications (PSV)

Before the Visit Obtain Information and Documents from Exporter Obtain Information and Documents from Exporter Complete name and address of the company to be visitedComplete name and address of the company to be visited Commodity involved in the transaction and control statusCommodity involved in the transaction and control status Contact person with complete address and telephone numberContact person with complete address and telephone number Contract, invoice or bill of saleContract, invoice or bill of sale

Before the Visit Obtain Information and Documents from Exporter Obtain Information and Documents from Exporter Product description, i.e. brochures, technical specificationsProduct description, i.e. brochures, technical specifications Shipping documents, such as airway bill or bill of ladingShipping documents, such as airway bill or bill of lading Export License including all conditionsExport License including all conditions

During the Visit Name of Company Visited Name of Company Visited Names and Titles of all people involved in the check Names and Titles of all people involved in the check Name of President and/or CEO of Company Name of President and/or CEO of Company Address of Company Address of Company Phone, Fax, of Company Phone, Fax, of Company Company Website Company Website Year Company was Founded Year Company was Founded

During the Visit Owners of Company or Parent Company Owners of Company or Parent Company Is it publically traded, on what market Is it publically traded, on what market If government agency, who are the subordinate to, what cabinet level ministry are they in If government agency, who are the subordinate to, what cabinet level ministry are they in If government agency, what is their mandate If government agency, what is their mandate Number of Employees Number of Employees Locations Locations Commodities the Company Deals in Commodities the Company Deals in

During the Visit If they are a distributor, what is their sales territory If they are a distributor, what is their sales territory Who else do they distribute for Who else do they distribute for Who are their customers Who are their customers Who are their competitors Who are their competitors Description of location(s) visited, i.e. office or factory facility Description of location(s) visited, i.e. office or factory facility Were the items physically inspected Were the items physically inspected

During the Visit If the items were serialized, what were the serials numbers inspected by Safeguards Team If the items were serialized, what were the serials numbers inspected by Safeguards Team Where were the items located Where were the items located What condition were the items in What condition were the items in Were the items in use or in storage Were the items in use or in storage Obtain Business cards from everyone Obtain Business cards from everyone Obtain Company Brochure, Catalog, Annual Report, etc. Obtain Company Brochure, Catalog, Annual Report, etc.

After the Visit Favorable: At the time visited, the consignee appeared to be a reliable recipient of the licensed commodities because in the case of a PSV the items were physically inspected and were being used in accordance with the license conditions. In the case of a PLC, the consignee appears to be a suitable recipient of the subject controlled items based on the on-site visit. Favorable: At the time visited, the consignee appeared to be a reliable recipient of the licensed commodities because in the case of a PSV the items were physically inspected and were being used in accordance with the license conditions. In the case of a PLC, the consignee appears to be a suitable recipient of the subject controlled items based on the on-site visit.

After the Visit Unfavorable: Subject of the end use check violated one or more license terms or conditions; or the subject of the end use check refuses to meet with USG personnel at posts or a Sentinel team to allow the end use check to be completed; or the responses to USG during on-site visit provide cause for concern about the suitability of the parties involved. Unfavorable: Subject of the end use check violated one or more license terms or conditions; or the subject of the end use check refuses to meet with USG personnel at posts or a Sentinel team to allow the end use check to be completed; or the responses to USG during on-site visit provide cause for concern about the suitability of the parties involved.