OIG-26-019-A - Recommendation 1

We recommend that the Assistant Secretary for Export Enforcement develop policy and guidance that:
a. Defines the methodology for target selection, including reviewing historical information when selecting a shipment for an end-use check and developing and conducting risk assessments to help inform the selection.
b. Requires documentation to support the analysis used to target high-risk shipments for end-use checks.
c. Defines the required process steps that export compliance specialists should perform when executing the end-use check process.
d. Requires that supporting documentation for end-use checks be maintained centrally to support the selection and final rating.
e. Requires that end-use check documentation include a justification when recommended actions are not implemented.
f. Requires completion of risk assessments to determine effectiveness of the targeting strategy.
g. Provides consistent methods for nominating or adding entities to the Unverified and Entity Lists for violations of export controls.
h. Describes the roles and responsibilities for supervisors that, at a minimum, describe how to verify that end-use checks align with BIS targeting priorities and guidelines, require that supporting documentation be included in a central repository, require documentation of changes to final ratings, and confirm that all required actions, including adding violators to concerned party lists, are completed before closing the end-use checks in IMS-R.