Question:We currently screen against the various Denied/Restricted Party Lists all new hire employees before hiring them. However, we are being encouraged to screen our active employees on a continuous basis. Do any members screen their employees on a routine basis, other than before hiring, and if so, how often and approximately how many employees does […]
Question:This question regards the subject of customer “walk ins” at US retail level sales outlets for “cash & carry” transactions. These transactions can be related to any retail business selling across the counter to the public. Unless the retail outlet has “reason to know” the goods are being purchased for subsequent exportation, what responsibility/liability does […]
Question;We are evaluating where to house personnel, long-term, for our order screening operations which consists of reviewing orders for denied parties and end uses. If we have multiple specialists screening orders from around the world, it appears we have two options: a regional presence in the Americas, Europe and Asia with personnel divided among the […]
Question:I’d like to know what the membership does when you have a business partnerwith a similar name as a Sanctioned/Debarred party. Does anyone have aprocedure they are willing to share? For example:Our business partner: XYZ IndustriesDebarred Party: XYZ Trading Company I Googled the debarred party but wasn’t able to find anything about whatthey did or […]
Question: In a distribution environment, what is the obligation to obtain end-user/use information, where you screen your customers, however, you are selling to an intermediary, broker, repair shop, etc? Do you have to ask the question of who your customer’s customer is and so forth? Per Commerce guidelines, if there are no red flags, “there […]
Question: Let’s say you use a 3rd party screening company, and they screen your entire consignee database (domestic and export customers) and the screening company comes back with a possible hit for example “ABC Forwarding – Toronto, Canada”, and sites the Federal Register notice. The FR notice specifically states: “…any person, firm, corporation, […]
Question: I have heard about a new BIS rule that places the responsibility on U.S.exporters to ensure that customers in a foreign country do not passproducts along to a party in the same country that is included on the U.S.Entity List without obtaining a BIS license. This may have an impact onproducts subject to the […]
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 […]
