1. 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

2. 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

3. 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

4. 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

5. 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

6. 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”

7. Special Agent – Office of Export Enforcement
Questions?
Donald Pearce
Special Agent – Office of Export Enforcement