BIS End-Use Checks: What Happens When an Export Control Officer Calls Your Customer
BIS has published a plain-language FAQ on its End-Use Check program, the on-site visits its Export Control Officers conduct at foreign consignees and end users of U.S.-origin items. This article explains what those visits are, what your foreign customer will be asked to produce, the statutory and regulatory authority behind the request, and the consequences when a check cannot be completed. It matters because the penalty for a failed check falls on the exporter’s ability to ship, not only on the foreign party being visited.
Key Takeaways
- An End-Use Check (EUC) is BIS verifying, on site and overseas, that your foreign customer is who it says it is and used your items the way the license or the EAR required.
- A failed or incomplete check does not need a finding of wrongdoing to hurt you. The customer can land on the Unverified List, license exceptions disappear, and every shipment then requires a UVL statement.
- Since October 2022, a check that stays incomplete for 60 days after Unverified List placement, because a host government blocks it, triggers Entity List proceedings.
- The exporter’s exposure is set before the visit ever happens: by the accuracy of the license application, the quality of the paper trail, and whether the foreign party was told what to expect.
- Diaz Trade Law prepares exporters […]
