the risk of Purpose
Knowing your end-user is one thning, knowing the end-use of your product is another.
When an export license is required, a legalized end-use statement is required.
When you are exporting to a destination of concern, and end-use statement should be standard.
- Human rights
- military end-use
- designed-for vs used-for
What are the risks?
Without an end-use statement from your client, you will not get an export license for your controlled items.
Your supplier can also ask an end-use statement from you as client, containing many restrictive conditions.
But what if your items are being used for the wrong purposes?
What if you send it to a end-users or country that is restricted by your supplier?
Investigating reporters and human rights organizations love a good story . It can really damage your brand if you cannot provide compelling evidence of a proper end-use due diligence.
It is more than just a statement
Most end-use statements are form free.
They vary from a simply one-pager to sofisticated legal text.
Others, like the US DSP-83, are strict as part of a license procedure.
They all have one thing in common.
They have a legal status in case of a possible violation.
You are being made aware of the restriction before you execute a transaction.
end-use management as a service
Managing your end-use statements is key, both on the import side of business, as on the export side of buiness.
How do you communicate statements you have signed with suppliers to your sales organization?
What do you do if the conditions in a statement are not fair to you?
Or what if your client does not want to sign your end-use statement?
Our Export Control Officers as a Service have a vast experience in setting up so-called EUS-management procedures and training your organization
