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Red Flags 

Possible indicators that an unlawful diversion might be planned by your customer include the following: 

  1. The customer or purchasing agent is reluctant to offer information about the end-use of a product. 
  2. The product's capabilities do not fit the buyer's line of business; for example, a small bakery places an order for several sophisticated lasers. 
  3. The product ordered is incompatible with the technical level of the country to which the product is being shipped. For example, semiconductor manufacturing equipment would be of little use in a country without an electronics industry. 
  4. The customer has little or no business background. 
  5. The customer is willing to pay cash for a very expensive item when the terms of the sale call for financing. 
  6. The customer is unfamiliar with the product's performance characteristics but still wants the product. 
  7. Routine installation, training or maintenance services are declined by the customer. 
  8. Delivery dates are vague, or deliveries are planned for out-of-the-way destinations. 
  9. A freight forwarding firm is listed as the product's final destination. 
  10. The shipping route is abnormal for the product and destination. 
  11. Packaging is inconsistent with the stated method of shipment or destination. 
  12. When questioned, the buyer is evasive or unclear about whether the purchased product is for domestic use, export or reexport. 
  13. You receive an order for “parts” or “components” for an end item in 9x515 or the “600 series.” The requested “parts” or “components” may be eligible for License Exception STA, another authorization, or may not require a destination-based license requirement for the country in question. However, the requested “parts” or “components” would be sufficient to service one hundred of the 9x515 or “600 series” end items, but you “know” the country does not have those types of end items or only has two of those end items. 
  14. The customer indicates or the facts pertaining to the proposed export suggest that a 9x515 or “600 series” item may be reexported to a destination listed in Country Group D:5 (see supplement no. 1 to part 740 of the EAR).
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