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EXPORT CONTROLS UK RED FLAGS The following is a list of what are known as Red Flags in export control. These are suspicious circumstances which would require an exporter to investigate the transaction further. The list is not exhaustive. If a Red Flag comes up then an exporter must investigate further and failure to do so may result in an illegal export. The United States Bureau of Export Administration - now the Bureau of Industry and Security – also has a list of red flags which are similar. You will note that most of these make simple commercial good sense and are questions which a seller or exporter should normally ask in any situation. For “goods”, also read “services”. A Red Flag occurs when: 1. The customer is reluctant to offer information about the end use of the goods. 2. The customer is reluctant to provide clear answers to commercial or technical questions which are routine in normal negotiations. 3. An unconvincing explanation is given as to why the goods are required, in view of the customer’s normal business or the technical sophistication of the goods. 4. Routine installation, training or maintenance services are declined. 5. Unusually favourable payment terms such as higher http://www.ukassignment.org/ price and/or lump sum cash payment are offered. 6. Unusual shipping, packaging or labelling arrangements are requested. 7. The customer is new to the exporter and knowledge about the customer is incomplete. 8. The installation site is in an area under strict security control or in an area to which access is severely restricted or is unusual in view of the type of equipment being installed. 9. There are unusual requirements for excessive confidentiality about final destinations, customer or specification of items. 11. The dealer is new to the exporter or has been evasive about customers, or the enquiry has come from an unusual source. 12. The end user is a military or government research body. 13. The order itself is unusual in any way – eg the quantity or performance capabilities of the goods ordered significantly exceed, with satisfactory explanation, the amount or performance normally required for the stated end use. There a number of points I would add to the list: 1. If the destination or identity of the customer or end user suddenly changes part way through the transaction, then that should be thoroughly checked out. 2. It is prudent to check for red flags at the outset of the transaction and once again at the point of export – when the goods are ready to leave the factory or warehouse. 3. Always build into contracts a provision which allows delay in the event an export licence has to be applied for; and always ensure the force majeur clause in a contract allows for government action, legislation and administrative procedures to be included as a force majeur event.#p#分页标题#e#
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