Stop me if you’ve heard this one. Your Business Development Manager (we’ll call him “Bob”) is at a military trade show somewhere in the Middle East. A guy from that region exchanges business cards with Bob, chats for a few minutes, then splits.
A few weeks later, Bob receives an email from the gentleman, asking for price and delivery terms for certain hardware, which will enable him to mount heavy machine guns into the backs of pickup trucks. He attaches this photo to the email.
He goes on to explain that he needs 100 of these mounts as soon as your company can ship them. These mounts are not something that your company normally makes, although you purchase similar items. Bob decides to stop by your office and discuss this scenario with you – the company’s Export Compliance Officer:
Bob: I met a guy at this trade show last month, and he wants me to quote 100 mounts to attach these guns to the backs of pickup trucks. I think they’re Russian. He sent me this photo.
You: You’re kidding, right?
Bob: No, I’m serious. What do you think?
You: We don’t make anything like that.
Bob: That’s the beauty of it! We have a supplier who can fabricate this for us. We could buy from them, mark it up, and make a nice chunk of change. The buyer wants these fast and he really doesn’t care about the price.
[At this point, Bob hands you the guy’s business card.]
You: Well, let’s see. His address is a P.O. Box in Dubai.
Bob: That’s right. I went to the website and it says “Under Construction.”
You: I just ran him through our comprehensive Denied Party Screening application and nothing comes up.
Bob: That’s good, right? No DPL hits?
You: Yes, but the first problem is, we can’t ship a weapons mounting platform to a P.O. Box.
Bob: Ok, what else?
You: Let me get this straight. You want us to quote a pass-through sale of 100 heavy weapons mounting systems from one of our suppliers, no value-added here, to a guy you only met briefly – in a foreign country - ship it all to a P.O. Box in Dubai, to a company that has no actual website, they don’t care about the price, they want it delivered ASAP, and we don’t even know what business they’re in?
Bob: Well … since you put it that way.
You: This picture was taken on a camera phone in somebody’s house!
Bob: So, you aren’t going to approve the sale?
You: Are you kidding?!? I’m going to forward this to the authorities! Now, are we done here?
Bob: Ok, ok! You don’t have to be rude about it!
With very few details changed, this actually happened. In fact, the photograph is the actual one from the real-world scenario – “laundry pile mattress” and all. So, how many red flags did you count?
If you still don’t see anything wrong with this proposed deal, or if the story sounds like something that has happened to you or your company, then you may want to invest in some Export Compliance Awareness Training for your organization.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.