Date post: | 27-Mar-2015 |
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End-Use VerificationEnd-Use Verification
Military Items Dual Use and Commercial Items
Controlled by the State Department
Controlled by the Commerce Department
U.S. Department of CommerceU.S. Department of Commerce
Bureau of Bureau of Industry and Industry and Security (BIS)Security (BIS)• Export Control Export Control
AttachesAttaches• Sentinel TripsSentinel Trips• Embassy Embassy
ChecksChecks
Export Control AttachesExport Control Attaches
Sentinel TripsSentinel Trips• Teams of two export control officials Teams of two export control officials • Travel to one or two countriesTravel to one or two countries
Embassy VisitsEmbassy Visits• Conducted by the Foreign Commercial Conducted by the Foreign Commercial
ServiceService
Red FlagsRed Flags Party to the transaction has previous enforcement issuesParty to the transaction has previous enforcement issues Party to the transaction is sanctioned by another Party to the transaction is sanctioned by another
governmentgovernment Party to the transaction has divisions or branches involved Party to the transaction has divisions or branches involved
in prohibited uses or located in prohibited destinationsin prohibited uses or located in prohibited destinations Party to the transaction has same or similar address to any Party to the transaction has same or similar address to any
of the aboveof the above Consignee or End-use is located in a transshipment pointConsignee or End-use is located in a transshipment point
Red FlagsRed Flags Unknown consignee on license applicationUnknown consignee on license application
Sensitive CommoditySensitive Commodity
The product's capabilities do not fit the buyer's line of The product's capabilities do not fit the buyer's line of business, such as an order for sophisticated computers business, such as an order for sophisticated computers for a small bakeryfor a small bakery
The item ordered is incompatible with the industrial base The item ordered is incompatible with the industrial base of the country to which it is being shipped, such as of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped semiconductor manufacturing equipment being shipped to a country that has no semiconductor industryto a country that has no semiconductor industry
Conducting the End-Use CheckConducting the End-Use Check
Pre-License Checks (PLC)Pre-License Checks (PLC) Post Shipment Verifications (PSV)Post Shipment Verifications (PSV)
Before the VisitBefore the Visit
Obtain Information and Documents Obtain Information and Documents from Exporterfrom Exporter• Complete name and address of the Complete name and address of the
company to be visitedcompany to be visited• Commodity involved in the transaction Commodity involved in the transaction
and control statusand control status• Contact person with complete address Contact person with complete address
and telephone numberand telephone number• Contract, invoice or bill of saleContract, invoice or bill of sale
Before the VisitBefore the Visit
Obtain Information and Documents Obtain Information and Documents from Exporterfrom Exporter• Product description, i.e. brochures, Product description, i.e. brochures,
technical specificationstechnical specifications• Shipping documents, such as airway bill Shipping documents, such as airway bill
or bill of ladingor bill of lading• Export License including all conditionsExport License including all conditions
During the VisitDuring the Visit
Name of Company VisitedName of Company Visited Names and Titles of all people involved in Names and Titles of all people involved in
the checkthe check Name of President and/or CEO of Name of President and/or CEO of
CompanyCompany Address of CompanyAddress of Company Phone, Fax, Email of CompanyPhone, Fax, Email of Company Company WebsiteCompany Website Year Company was FoundedYear Company was Founded
During the VisitDuring the Visit
Owners of Company or Parent CompanyOwners of Company or Parent Company Is it publically traded, on what marketIs it publically traded, on what market If government agency, who are the If government agency, who are the
subordinate to, what cabinet level ministry subordinate to, what cabinet level ministry are they inare they in
If government agency, what is their If government agency, what is their mandatemandate
Number of EmployeesNumber of Employees LocationsLocations Commodities the Company Deals inCommodities the Company Deals in
During the VisitDuring the Visit
If they are a distributor, what is their If they are a distributor, what is their sales territorysales territory
Who else do they distribute forWho else do they distribute for Who are their customersWho are their customers Who are their competitors Who are their competitors Description of location(s) visited, i.e. Description of location(s) visited, i.e.
office or factory facilityoffice or factory facility Were the items physically inspectedWere the items physically inspected
During the VisitDuring the Visit
If the items were serialized, what were the If the items were serialized, what were the serials numbers inspected by Safeguards serials numbers inspected by Safeguards TeamTeam
Where were the items locatedWhere were the items located What condition were the items inWhat condition were the items in Were the items in use or in storageWere the items in use or in storage Obtain Business cards from everyoneObtain Business cards from everyone Obtain Company Brochure, Catalog, Obtain Company Brochure, Catalog,
Annual Report, etc.Annual Report, etc.
After the VisitAfter the Visit
FavorableFavorable: At the time visited, the : At the time visited, the consignee appeared to be a reliable recipient consignee appeared to be a reliable recipient of the licensed commodities because in the of the licensed commodities because in the case of a PSV the items were physically case of a PSV the items were physically inspected and were being used in inspected and were being used in accordance with the license conditions. In accordance with the license conditions. In the case of a PLC, the consignee appears to the case of a PLC, the consignee appears to be a suitable recipient of the subject be a suitable recipient of the subject controlled items based on the on-site visit.controlled items based on the on-site visit.
After the VisitAfter the Visit
UnfavorableUnfavorable: Subject of the end use : Subject of the end use check violated one or more license check violated one or more license terms or conditions; or the subject of terms or conditions; or the subject of the end use check refuses to meet with the end use check refuses to meet with USG personnel at posts or a Sentinel USG personnel at posts or a Sentinel team to allow the end use check to be team to allow the end use check to be completed; or the responses to USG completed; or the responses to USG during on-site visit provide cause for during on-site visit provide cause for concern about the suitability of the concern about the suitability of the parties involved. parties involved.