The Export Administration Regulations UVL (Unverified List) controls the export, reexport or transfer (in country) of items to listed parties. Furthermore, parties on this list are not eligible for any license exemptions. Failure to comply with these regulations can result in civil and criminal penalties, imprisonment, and debarment from export activities.
Conducting Export Activities to UVL Entities
Export activities to entities appearing on the Unverified List (UVL) require the exporter, transferor, or rexporter to obtain a UVL statement from the listed person. These statements, recorded in a document, are valid for multiple exports, reexports, or in country transfers for a single item. The document must be signed and dated by the UVL party. Specific data for this document include: name, physical address, agreement not to engage in any prohibited end use, statement of end user, end use, and country of ultimate destination.
The listed person must certify that they have sufficient authority to bind the party legally. They must also agree to Post-Shipment Verification (PSV) to be conducted by or on behalf of the Bureau of Industry and Security (BIS). PSVs are conducted by officials in person to verify that exported items arrive at the intended destinations.
Denied Parties Screening
UVL controls are yet another example of why organizations need to conduct denied parties screening. This activity is an essential practice for ensuring regulatory compliance to U.S. law. Screening is performed to restrict or prohibit U.S. individuals and organizations from shipping products or providing services to parties listed on denial, debarment, and blocked persons lists.
The United States Government maintains a number of lists of sanctions and debarred parties. These are maintained on the Consolidated Screening List (CSL). Additionally, a number of private vendor solutions are available that provide screenings and alert users to any change in status.
CVG Strategy Export Compliance Management Programs
Export Compliance is an important subject for businesses engaged in sales of items that are intended for international sales or could result in international sales. Failure to comply with regulations can result in criminal prosecution including imprisonment and fines. It can also result in civil penalties and disbarment from export activities. Your business cannot afford to have its reputation ruined by a failure to comply.
CVG Strategy can help you in understanding Export Administration Regulations UVL requirements and help you in establishing a coherent and effective export compliance system. We can perform export control classifications, perform audits, and educate your team. Regardless of whether your business falls under EAR or ITAR, CVG Strategy has the expertise to help. Contact Us with you export regulation questions.