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Be Aware of Your Exports: BIS and DDTC Cracking Down on Export Violations to Russia

Saint Basil's Cathedral in Russia

Shipments to Russia and Ukraine are still being heavily scrutinized by the Bureau of Industry and Security (BIS) and the U.S. State Department of Defense Trade Controls (DDTC). The inspection has increased since new sanctions were issued to Russia and Ukraine in December 2016. Therefore, to avoid export violations it is crucial to ensure your organization practices due diligence in regards to U.S.-origin items being transshiped or reexported to these areas.

Here are a few preventative measures you can take to minimize the chances of unknowingly enabling illegal diversion of your exported goods to Russia. The full version can be found here.

  • Pay attention to any discrepancies between the destination country and country from which an order is placed or payment is made. If the countries do not match, it’s possible that someone is planning to illegally divert your exported goods to a different country, such as Russia.
  • Be wary if a freight forwarder’s office or address is listed as the item’s final destination. It is your duty, by law, to investigate further. Do not proceed with the transaction before asking the purchaser about the item’s end user, end use, and ultimate destination.
  • When looking into the end destination of the item, an exporter should take a close look at the e-mail address, telephone number country codes, and languages used in customer communications or websites. If any of these details suggest a destination country other than what you have been told by the customer, you should be cautious about going through with the transaction.
  • Exporters are advised to always screen their customers. The U.S. government has provided a user-friendly tool to help in the consolidated export screening process.

Do you need help with developing your export compliance manual? Reach out to Mohawk Global Trade Advisors.

By Danielle Passage

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