PURPOSE: To confirm the process for the handling of all requests for quotes, sales inquiries, and product orders to ensure Construction Specialties remains in full compliance with OFAC laws and regulations
SCOPE: 100% of all quotes and/or inquiries for sale of company product
PROCEDURE
1. For all employees providing a quote for sale of merchandise:
- Upon receipt of a Request for Quotation:
- Contact the Export compliance team for the following:
- Request them to
- screen all partners listed in the transaction (company name, individual requesting product, and any other person identified in the transaction); confirm there are no “hits” against the denied party screening (DPS) before proceeding with the inquiry;
- Confirm the person requesting the quote is not from an embargoed nation or a national thereof who is not also a U.S. citizen or permanent resident alien, state that you cannot accept or process orders from such nations and report such contact to the Compliance Officer.
- screen all partners listed in the transaction (company name, individual requesting product, and any other person identified in the transaction); confirm there are no “hits” against the denied party screening (DPS) before proceeding with the inquiry;
- Request them to
- Include the following in your response to the prospective purchaser, to ensure full compliance with U.S. global trade restrictions:
- You may not include any boycott-related language in any order or other communications with us;
- Upon receipt, this product may not be resold, transferred, transshipped, or reexported to any country that is embargoed by the United States nor to any natural person, business entity, organization, or other party designated on a U.S. Prohibited Party list.
- You may not include any boycott-related language in any order or other communications with us;
- Contact the Export compliance team for the following:
- At the time of shipment, screen the Purchaser, Ultimate, and Intermediate consignees (including the vessel or airline for shipment) against the Prohibited Party databases.
- Do screening at the time of shipment for all orders, including those from existing customers who have been previously screened.
- Document in the order file the results of the screening.
- If you discover post-shipment that the ordering party or anyone else in the distribution chain for the party is a Prohibited Party or has become part of an embargoed nation, report this occurrence to us.
- if you receive any indication post shipment that the products are being diverted, transshipped, or reexported from the destination country to an embargoed country or Prohibited Party, you must promptly notify us.
- Confirm that FEJC is filing the Exporter Electronic Information (EEI) through the Automated Export System
- If you are using a freight forwarder for the shipment that has been chosen by the foreign buyer, ensure that you have structured a Routed Export Transaction.