General Lab Information

Red Flags for Export Control

Red Flag Indicators

  • Reluctance to share information about the end-use, including reluctance to complete an end-user form
  • Receiving unsolicited emails from unknown individuals, including those who identify themselves as academics or students, asking for information on, assistance with, or sharing of know-how/technology/data with potential military applications.
  • Collaborator/Sponsor providing or intending to provide classified information
  • Use of personal email accounts instead of company email addresses
  • IP addresses that do not correspond to a reported location data
  • Are they phishing for sensitive technology?

If there are red flags, you need to inquire regarding the suspicious circumstances and ensure appropriate end-use, end-user, or ultimate country of destination. If the red flags cannot be explained or justified and you proceed with the transaction, you run the risk of violating the EAR or ITAR.

Employees need to be aware of regulations and compliance issues and should not “self-blind” themselves by not asking for end-user information. This does not insulate BNL from liability and may be considered an aggravating factor in an enforcement proceeding.

If you continue to have reason for concern after your inquiry, then refrain from the transaction and submit all the relevant information to the Export Control Office and we can continue the evaluation.

All Red Flags MUST be investigated and resolved!