Thanks for the clarification capturing the gist of my original comment. I was not attempting to advocate a position for terminating the employment of enforcement officials and investigators in favor of an enforcement system relying solely on anonymous letters.

I do advocate a program to help trolls learn to read language within the context it’s presented.

Way outside the Beltway where I live, freight forwarders compete for business by assuring their customers that they are a low-cost one-stop-shop for all their export “documentation” needs, and then often hand off the work to low-paid undereducated clerical staff who are under pressure to handle a high volume of documents for a relatively small amount of money. They treat an export classification and controls in general, as merely a paper exercise. When they get it wrong, they then try to blame the customer.

That said, I’ve known some freight forwarders who are exceptionally knowledgable and competent, and others who are careful to not do export control work themselves but clearly shift responsibility to their customer (at least in the boilerplate to the agreements).

What? Come again! Do freight forwarders “stab their clients in the back” when they are asked to provide true and correct information about an export to the government, and do so? Whoa!! Please note, providing false information to an executive branch investigator is a felony, 18 USC 1001. Not to mention that a freight forwarder could get in all sorts of other trouble for not complying with an subpoena or enforcement request. Actually, many freight forwarders do get in trouble for providing false and misleading information on SEDs.

Also, another comment:

“Just goes to show that BIS does not necessarily need investigators in the field to discover violations.” Comment by Matthew J. Lancaster — October 31, 2007

Again…What? I cannot even respond to this absurd comment. I guess that most police departments with tip lines don’t need police officers on patrol or detectives in the field.

[Comment edited by blog owner for spelling errors and incivility]

Clif Burns responds:

I think that our commenter “OOOPS!”, who trolls here frequently under other names (but the same IP Address) and hides behind a fake email address, has misconstrued what Mike and Matthew said. Matthew wasn’t recommending getting rid of export enforcement officials, like, presumably, “OOPS!”, but was instead making the reasonable point that there are other ways of getting caught and that companies should be aware of that. And Mike wasn’t suggesting that freight forwarders should lie, rather he was noting that often the forwarder goes unsolicited to BIS or DDTC to disclose his customer’s violation. This is an area of controversy, but I don’t think it’s frivolous to suggest that when a freight forwarder gets a package addressed, say, to Iran, that the forwarder should return it to his customer and note that such packages can’t go without a license. Now, if the freight forwarder returns the next day and the customer wants to ship the same package to the UAE, well, then a trip to BIS or DDTC by the freight forwarder might well be in order

AES may change things in the future, once it gets fully implemented, because it will give the agencies the ability to look at exports in real time (Unlike the days when I and my team had to go to Germantown, ND, to look at SEDs on microfiche). But angry workers are probably always going to be the best source of leads.

Just goes to show that BIS does not necessarily need investigators in the field to discover violations. Has anyone ever put together any metrics to try to figure out how many investigations and/or penalties stem from third party complaints to BIS?