While the government is doing its job to keep controlled goods out of the wrong hands, all exporters must do their part to support these efforts and facilitate successful end-use checks.
End-use checks: Often forgotten, but tremendously important
End-use checks are first relying on the so-called End-Use Certificates (EUC) that the end-user or, in case the end-user is not yet known, the consignee or intermediary is filling in and signing. This end-use statement certifies that a buyer is the final recipient of exported materials and has no intention of re-exporting said materials to anyone else. This document can play a vital role in preventing export violations and providing proof of your due diligence. But do you know where to find templates to use for these EUC? Are they different depending on the country where you are in or where your end-user is established? What about digital signatures? How do you check if the EUC is signed by persons having the power to legally bind the end-user? Do authorities need to get the originally signed EUC, or is a copy (or certified copy) enough? How do you react if the end-user is simply putting "civil use" in the relevant field? How do you request and get additional information?
An end-use check implies that you verify if the company is a reliable end-user. How do you discover more information about the parties involved? Are you checking business registration? Excitement about a potential new customer, or concerns about causing offense should not stop you from making this request. An organization with nothing to hide should have no qualms about sharing. Are you reviewing social media sources? It is amazing what you can learn about a company or individual from browsing Twitter, Facebook, LinkedIn and other sites. Empowering yourself with knowledge about who you are doing business is always worth the time and effort.
It should go without saying that you have to screen end-users, also when they are not your direct customers. Do you have access to the most current government watch and sanctions lists? Does your screening process include re-screening? The person you do business with today could appear on a restricted party list tomorrow.
That you are able to detect a suspect transaction or a non-reliable end-user means that you have put into place a series of indicators, or red flags, that you are regularly reviewing. If not, where do you find the red flag questions to ask? Are your staff members aware of these red flags? Are the red flags assessments communicated to your company's export control officer, and integrated into the decision-making process before shipping your product, technology or software?
RespectUs, a complete online solution to facilitate end-use(r) checks
Our End-use Checks module in the RespectUs platform is guiding you along the way. It has designed a series of red flag questions about your product, its end-use, its end-user, shipment, finance and contract conditions. You may store and download the report. Communicating the report to your export control officer or management will make sense if red flags have appeared and need to be processed in order to take the final decision about serving your customer.
It also offers different end-use certificate templates. You may invite your supplier through the platform to send you the appropriate form. You may store the EUCs in your dashboard, along with the information collected for a particular transaction and product. This makes the entire process easier and faster.
The RespectUs solution allows you to operate name checks or sanctions assessments for your product through the platform. A link with the customer profile you have already completed in the platform is established.
In short, the RespectUs End-use Checks module is:
an innovative tool to collect and process all information about the end-use of your product, technology or software,
allowing you to prove to the authorities that you have performed all required end-use checks
completing your internal compliance measures arsenal
mixing questionnaires, forms, templates and name check tools
easy to use
responding to the guidelines of authorities worldwide about knowing your product, your customer and end-user.
Test us. Challenge us. Give us feedback so that we can improve and design this module according to your specific needs.
For the RespectUs team,
Patrick Goergen, CEO
Next to come in this series:
D-6: Risk Assessment, designed by RespectUs, to determine your export control compliance risk level
Did you miss part(s) of the series? Read here the last blogs:
1 March 2023: D-14 RespectUs is opening subscriptions on 15 March 2023