Denied parties and your ITAR policy
March 6, 2012
By Don Buehler, Export Solutions
There’s nothing like the recent case of major freight forwarding companies being added to the EPLS to bring home the importance of denied parties screening for your company.
I’ve been involved with many clients’ denied parties list (DPL) screening programs for a number of years, and it’s easy to be lulled into a sense of thinking that the risks of a problem are very low. (After all, you can screen thousands of entries and only find a handful of actual matches.) Of course, both the ITAR and the EAR restrict U.S. persons from engaging with these parties.
Recently, however, I was reminded about the potential consequences of not treating this issue vigilantly. Last year, we screened a client’s list and found no real matches. Shortly thereafter, our client accepted product from a new supplier, but they did not perform a screen of this entity as required by their ITAR policy. After accepting the materials and starting the process of shipping the materials out of the country, the supplier informed our client that they had actually been debarred by DDTC! Fortunately, the client stopped the shipment and retrieved the goods before they left the country. However, this points out the inherent risks of not following a proscribed ITAR policy – every time – and not paying proper attention to your DPL screening processes.
In recent weeks, Export Solutions has partnered with eCustoms to provide screening services for our clients. Their software is extremely user friendly and ensures that you’ll never get a surprise like the one I described above. This is a cost-effective, powerful service which goes hand-in-hand with Total Managed Support – our outsourced export compliance solution.
Many clients are already enjoying the benefits of this program. Contact us today to schedule a free demo, and learn how it can help you, too.
Don Buehler is founder and president of Export Solutions, Inc., a consultancy firm which specializes in helping companies comply with ITAR and EAR. Follow Don on Google+.