Question: Is it acceptable compliance procedure for a US exporter to screen a list of names and addresses of foreign affiliates and designated freight forwarders on an annual, semi annual, quarterly or monthly basis in lieu of screening individual orders or shipments.? If so, what is a reasonable interval and what records should be kept?
Question: We are a US company with operations and employees all over the globe. My questions are: (1) Do you perform screening of your employees against the restricted party lists? (2) How? (3) What are the privacy and / or consent issues that you have had to deal with, particularly for employees located in Europe? […]
Question: I am hoping that the membership can help out on an internal debate we are having. If we send out promotional material about EAR99 products to a group of names on a rented list what is our obligation to screen these individuals? The concern is that the rented list will be provided […]
Question: Effective Date vs. Published date vis-à-vis the DPL The denied party isn’t published in the federal register for a week or two after the effective date, how can the exporter be held liable if he ships to the denied party a day after the effective date? Shouldn’t the effective date in actuality, be the […]
If your company does all of it’s export screening for denied parties,embargos -even domestic and intra-company. If an order comes in from Gabon in Africa, or from Boreno in the Pacific Islands – does your company prefer that you do not ship to those locations? In reviewing our salesorders, unless we know that there is […]
What type of screening is required for a foreign branch that designs and manufactures its own product? If there is no U.S. content in the product are we still required to screen their customers.
How do members check denied party lists (and how many of the various export lists are checked)? And do you check for each exported shipment?
Can anyone tell me if they do Denied Parties screening for their imports, and if so, what is the justification?
How often should denied party (and other) screenings be performed? 99% of our products are regulated by the ITAR. We have been told that there should be a check at first contact, RFQ, delivery of RFQ, when the order is placed and before each shipment. Is this excessive? What do other companies actually do? Do […]
I’d like to find out if anyone has used a formal statement to deny or a response to a potential customer’s request for a quote, because they would not divulge or claim they don’t know the ultimate destination if we were to sell them our product(s). Would anyone like to share a written statement / […]
Can the membership provide feedback on whether they check all domestic transactions against the denied persons and other applicable lists? How is the check performed? (ex: third party software package) Also, how did you get management buy in for this expense?
QUESTION ON DPL SCREENEING / ENDUSE-USER: I understand that to ensure a company exports legally that the denied parties’ lists should be checked. Companies should also inquire about the end use of their products and use the destination control statement on their invoices, etc. Let’s say the product is EAR99 – NLR. What about asking […]
