Do we take on face value what our customer informs us is the end-use?
(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)
That is a very good question ! There is only so much due diligence that you can undertake, and as long as you could prove to the authorities that you had done what you could to confirm the stated end use then I wouldn’t think that you could be held responsible.
If you are applying for a SIEL then the ECO and the other government departments that review the application will be undertaking due diligence as well (and they will have access to sources that you don’t), but a signed undertaking and screening against denied parties lists should help give you that feeling that all is what it seems.
I can see from your question that you are exporting and whilst unfortunately I cannot help directly you with your question. I can help you save money and time on your international payments and foreign currency requirements. We also give guidance on the markets so please let me know if you would like to arrange a call to discuss this further.
If you have suspicions about the end use and your items are not on a control list you can apply for the End Use Advice Service via https://www.spire.bis.gov.uk/spire/fox/espire/LOGIN/login. We may ask you to make a full licence application when we have completed our searches.
Your end user will be checked out by Export Control Organisation in all licence applications as a matter of routine.
Additionally this guide will provide advice about how to look out for suspicious enquiries. https://www.gov.uk/government/publications/compliance-code-of-practice