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

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End-Use End-Use Verification Verification
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Page 1: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

End-Use VerificationEnd-Use Verification

Page 2: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

Military Items Dual Use and Commercial Items

Controlled by the State Department

Controlled by the Commerce Department

Page 3: End-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

Page 4: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

Export Control AttachesExport Control Attaches

Page 5: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 6: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.
Page 7: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 8: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 9: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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)

Page 10: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 11: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 12: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 13: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 14: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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

Page 15: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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.

Page 16: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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.

Page 17: End-Use Verification. Military Items Dual Use and Commercial Items Controlled by the State Department Controlled by the Commerce Department.

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.


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