CES Professional Ethics & Compliance 3

Question 1

A robust export compliance program (ECP) should include all of the following EXCEPT:

Accepted Answer

A policy of never disclosing violations to regulators

Answer

Effective ECPs include written policies, management support, training, recordkeeping, and a commitment to timely disclosure of violations—concealment is not a best practice.

Question 2

Which of the following is considered a 'red flag' that should prompt heightened due diligence before proceeding with an export transaction?

Accepted Answer

A buyer who is unusually insistent on paying cash and avoiding documentation

Answer

A desire to avoid documentation or pay in cash is a classic red flag that may indicate the buyer is attempting to conceal the true end use or end user.

Question 3

The BIS 'Know Your Customer' guidance advises exporters to investigate a transaction further if the buyer:

Accepted Answer

Is reluctant to provide information about the end use of the product

Answer

Reluctance to provide end-use or end-user information is a key red flag in BIS's Know Your Customer guidance, signaling possible diversion.

Question 4

In export compliance, 'deemed exports' refer to the release of controlled technology or source code to:

Accepted Answer

A foreign national within the United States

Answer

A deemed export occurs when controlled technology is released to a foreign national in the U.S., which is treated as an export to that person's home country under EAR.

Question 5

When a freight forwarder is preparing export documents, who bears ultimate legal responsibility for the accuracy and legality of the export?

Accepted Answer

The exporter of record

Answer

The exporter of record is legally responsible for the accuracy of all export documentation and compliance with export control laws, regardless of who prepares the documents.

(CES) Certified Export Specialist Practice Test

(CES) Certified Export Specialist Practice Test

CES Professional Ethics & Compliance 3