Comments on: BIS Announces New Designations to Entity List http://www.exportlawblog.com/archives/433 Latest News on DDTC, BIS, OFAC, and other export law matters Wed, 08 Sep 2010 03:51:32 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Hamish Jackson http://www.exportlawblog.com/archives/433/comment-page-1#comment-21172 Hamish Jackson Thu, 11 Dec 2008 09:21:23 +0000 http://www.exportlawblog.com/?p=433#comment-21172 A classic example for a "Due Diligence" class: 2 recognisably commercial addresses and one less so. http://maps.live.com/ put the postcode in under "Locations" and have a look at the "Birds Eye View" photograph then match up against the likely trade type. Your 1st selection shows what appears to be a residential "mews" address instead of a "road" address, the second shows a commercial premises on the correct road and the third post code shows a residential address completely different to the commercial address quoted, then the 1st selection is the only one registered at "Companies House" under the name given. Then again if you look up the addresses alone for example you get: Bee Craft Shipping Companies (Head Office) based in the Second Way area of Wembley Tel: 020 89009400 Address: Unit 6 Metro Trading Centre, Second Way Wembley Middlesex HA9 0YU or Purcells 4 Quex Road London NW6 4PJ Where Purcells are a firm of accountants and most companies use their Accountants as their registered address. This lack of clarity will potentially get some people a lot of unwanted and probably unwarranted problems. Slightly better communications from BIS would be appreciated or at least a Reason For Concern so that reasonable due diligence can be performed by the exporter. i.e. is the subject matter IED support, Iranian Aircraft parts or what? Or is BIS fishing after picking up some gossip from intelligence. If they know enough that they are happy to publish they should know enough to be able to publish accurately. A classic example for a “Due Diligence” class: 2 recognisably commercial addresses and one less so. http://maps.live.com/ put the postcode in under “Locations” and have a look at the “Birds Eye View” photograph then match up against the likely trade type. Your 1st selection shows what appears to be a residential “mews” address instead of a “road” address, the second shows a commercial premises on the correct road and the third post code shows a residential address completely different to the commercial address quoted, then the 1st selection is the only one registered at “Companies House” under the name given.

Then again if you look up the addresses alone for example you get:
Bee Craft
Shipping Companies (Head Office) based in the Second Way area of Wembley
Tel: 020 89009400
Address: Unit 6 Metro Trading Centre, Second Way Wembley Middlesex HA9 0YU
or
Purcells
4 Quex Road
London
NW6 4PJ
Where Purcells are a firm of accountants and most companies use their Accountants as their registered address.

This lack of clarity will potentially get some people a lot of unwanted and probably unwarranted problems.

Slightly better communications from BIS would be appreciated or at least a Reason For Concern so that reasonable due diligence can be performed by the exporter. i.e. is the subject matter IED support, Iranian Aircraft parts or what?

Or is BIS fishing after picking up some gossip from intelligence. If they know enough that they are happy to publish they should know enough to be able to publish accurately.

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