Know Who You Are Doing Business With

By In Insight On 12th April 2023

Tensions with Russia, China, North Korea, and other countries are placing a keen government focus on corporate compliance programs. There are increased risks in this type of work, where we would have considered it business as usual. 

It is vitally important to know who your shippers are, who their consignees are, and the types of commodities you are shipping.   

Do we know our shippers? Do we know who are the owners and board members? Does the company participate in or understand the various security programs and organizations such as:

  • Customs-Trade Partnership Against Terrorism (CTPAT)
  • Transportation Security Administration (TSA)
  • Department of Commerce (DOC)
  • Food and Drug Administration (FDA)
  • Bureau of Industry and Security (BIS)
  • Department of Homeland Security (DHS)
  • Science and Technology (S&T)  

Do we know who are the overseas consignees? Do we know who are their principals? Do we know who they are doing business with? Are they participating in security programs in their own countries?  

Have all management, employees, contractors, and temporary employees been vetted through national security programs and deemed safe?  

Are we ensuring that sensitive information is not being exposed to non-U.S. citizens or other personnel who do not live under the jurisdiction of U.S. Federal Law?  

What commodities are being shipped, and could they be used for nefarious reasons?  

Please consider whether or not the commodities could be used to threaten U.S. interests.  

  1. Cyber security, including chips and AI technology   
  2. Implements of war, vehicles, arms, missiles, and bombs   
  3. Chemical or biological attacks   
  4. Illicit drug trade   
  5. Food security  

There are many ways we can unknowingly violate the various laws and rules, which seem to change daily, so we all need to be vigilant in knowing who we do business with.  

A recent Department of Justice article advises that an additional 25 new prosecutors are being hired to investigate export control violations and economic crimes and will be working with the Bureau of Industry and Security to identify possible violations.  

NNR participates in several programs, including restricted party screening, CTPAT, and TSA, to assist in protecting our supply chain. However, we also need to ensure that our shippers and consignees understand their rights and responsibilities in keeping the nation safe, as they know their commodities and trading partners better than we do. 

Ike Miura

Export Compliance Manager 



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