THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

April 2012

What to do when BIS special agents pay an ‘outreach’ to your company

An outreach visit may be a sincere effort on the part of BIS to educate you on your compliance obligations. On the other hand, it may be the first in a chain of events that results in your company..

Your day as an export compliance manager starts like any other. You check your email, return some phone calls, and take care of pending business. Suddenly, the office receptionist calls. Special agents from the U.S. Department of Commerce’s Bureau of Industry and Security (‘BIS’) have arrived for an unannounced ‘outreach’ visit. You politely welcome them, escort them to a conference room, answer all of their questions, and carefully listen to what they have to say. You think that’s the end of it. But several months later, you receive a charging letter from BIS that details a number of export control...

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