"Red flags" relating to suspicious enquiries
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Being vigilant for signs of suspicious enquiries or orders is vital for countering the risks of the proliferation of Weapons of Mass Destruction, their means of delivery, and the destabilizing accumulations of conventional weapons. Sharing such information with your competent authority is highly recommended and may in some cases be mandatory under EU and national laws and regulations. |
In case of doubt, consult with the competent authority
The below non-exhaustive list of questions is based on existing best practice and is derived from:
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The Wassenaar Arrangement list of advisory questions for industry (Agreed at the 2003 Plenary) |
The 2010 Compliance Code of Practice (Department for Business Innovation & Skills, United Kingdom)
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ICP approaches from competent authorities in other EU Members States.
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End use and End user:
ü the customer is new to your company and your knowledge about him/her is incomplete or inconsistent or it is difficult to find information about the customer;
ü the stated end user is a trading company, distributor or based in a free trade zone;
ü the end user is tied to the military, the defense industry or a governmental research body and the stated end use is civilian;
ü the customer seems not to be familiar with the product and its performance characteristics (e.g. an obvious lack of technical knowledge);
ü the contact information in enquiries (e.g. phone numbers, e-mail, addresses) is located in other countries than the stated company, or changed to that over time;
ü the company has a foreign company name (e.g. in a language that is unexpected for the country where headquarter is located);
ü the company website lack content in comparison to what is normally found on a legitimate company website;
ü the customer is reluctant to offer information about the end use of the items, provide clear answers to commercial or technical questions which are routine in normal negotiations or to provide an end user statement;
ü an unconvincing explanation is given as to why the items are required, given the customer’s normal business, or the technical sophistication of the items;
Shipment:
ü unusual shipping, packaging or labelling arrangements are requested; usual incoterms for shipment, the sealing of containers/trucks and the confirmation of receipt by the consignee/end-user are refused;
Finance and contract conditions:
ü unusually favorable payment terms such as paying an unreasonably high price, full payment in advance or want to do a full cash payment immediately;
ü the payment is made by other parties than the customer or stated intermediaries and follow another route than the products;
ü routine installation, training or maintenance services are declined;
ü the installation site is in an area under strict security control or is in an area to which access is severely restricted, or is unusual in view of the type of equipment being installed;
ü there are unusual requirements for excessive confidentiality about final destinations, or customers, or specifications of items;
ü there are requests for excessive spare parts or lack of interest in any spare parts;
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Sharing information and suspicious enquiries with your competent authority is highly recommended and good business practice. In case of doubt, consult with the competent authority. Trust your instincts, you know best what is suspicious within your business area. |