While we can all certainly agree that we’re not as desirable as Richard Gere tooling down the Pacific Coast Highway in his Giorgio Armani behind the wheel of a Mercedes-Benz 450 SL, I think everyone can agree that one simple phone call to your favorite compliance team might easily be the best call you’ll make all week….or even all year!
Let’s slip on your imagination hat and step into the way back machine to take a look how the companies below could have saved so much money by asking a simple question. Close your eyes and pretend we’re not in the middle of a pandemic complete with a dash of murder hornets. No mask needed for this journey.
- What if FLIR would have made that one call and asked, “Should our HR folks collect citizenship information necessary to determine licensing requirements for foreign person employees”?
The Penalty: $30,000,000.
- What if Pratt & Whitney would have made that one call and asked, “Is software modified for a military platform application considered a defense article”?
The Penalty: $75,000,000.
- What if Titan would have made that one call and asked, “Do you think a $1.2 million commission on a $2.5 million sale might be considered disproportionate”?
The Penalty: $1,500,000.
- What if Cryofab or Teledyne LeCroy each would have made that one call and asked, “Do you offer screening services”?
The Penalty: $35,000 and $75,000, respectively.
- What if MHz Electronics would have made that one call and asked, “We had a visit from the FBI; do we really need a written export compliance program”?
The Penalty: $10,000.
- What if Weiss, MHz, and Envirotech each would have made that one call and asked, “Do I need to worry about manufacturing equipment”?
The Penalty: $75,000, $10,000, and $500,000, respectively.
- What if Navigators Insurance would have made that one call and asked, “Do we really need a formal OFAC compliance program”?
The Penalty: $271,815.
- What if Wind River would have made that one call and asked, “What’s the big deal with the know your customer rule”?
The Penalty: $750,000.
- What if Halliburton would have made that one call and asked, “Can my foreign subsidiaries sell to a concession which has a Cuban interest”?
The Penalty: $304,706.
- What if Dreco Energy would have made that one call and asked, “Why can’t I ship EAR99 items to Canada, and then ship them to Iran”?
The Penalty: $2,500,000.
- What if Milwaukee Electric or Axis Communications each would have made that one call and asked, “What are the country restrictions on ECCN 6A003”?
The Penalty: $301,000 and $700,000, respectively.
Wouldn’t it be nice if you could pick up the phone and ask your trusty consultant a seemingly simple question and get back a straightforward, specific, and sure answer? International trade is becoming even more complex and for companies, both large and small, the regulations can be difficult to navigate. Our team of consultants are experts in the field. They have real-world, hands-on experience and are valuable resource for all of your compliance questions.
When reading that the above questions ultimately related to fifteen serious and costly compliance violations, it seems almost silly that the unlucky named offenders didn’t just pick up the phone and “Call Me.” It could have saved them so much money.
If you have a question to ask, contact Export Solutions for a free consultation. We’ll be happy to help improve your company’s compliance and avoid risky scenarios like those described above.