Appendix 3

DIVERSION RISK & RED-FLAG CHECKEmployee Initials/date:______

Customer Name: / Account #:
City, State: / Country: USA

When any of the following Red Flag Indicators have been identified and follow-up inquiries have not satisfactorily resolved doubts, you should not proceed with the customer set-up, order or export in question.

Contact the Manager, International Compliance for resolution at (804) 935-2391. If this person is unavailable, contact the Manager, Product Compliance at (804) 935-2156.

KNOW YOUR CUSTOMER - International
The end use or end-user of the product is located in a sanctioned country. (Cuba, Iran, Sudan, Syria, North Korea) / YES___NO_X__
The customer, salesperson, or purchasing agent is reluctant to offer information about the end use (or end-user) of a product. / YES___NO_X_
A freight forwarding firm is listed as the product’s final destination. / YES___NO_X_
The shipping route is abnormal for the product and destination. / YES___NO_X_
Packaging is inconsistent with the stated method of shipment or destination. / YES___NO_X_
DOCUMENT REVIEW
The purchase order is written to another company or there are odd instructions about billing or some other aspect of the transaction. / YES___NO_X_
The documentation, PO, email or other attachments references a third party company involved in the transaction that we are not familiar with. / YES___NO_X_
Does the PO contain illegal Arab League boycott of Israel language or provisions or other language signifying discrimination based on race, religion, gender, or nationality? / YES___NO_X_
KNOW YOUR PRODUCT
Answer the questions below for the following chemicals: 1121, 1222, 3003, 3501, 3502, 3503, 3505, 3506, 3508, 3509,
BL1257, BL151, BL1541, BL1542, BL1543, BL1544, BL1546, BL1548, BL1549, BL1553, BL1554, BL1555, BL1564, BL1565, BL 8201, BL8703, BL8850, BL8860, BLG11541,
BLG11549, BLG18703, BLS1544,
CD22,
CL18, CL2890, CL455, CL4550, CL550,
CN130, CN150, CP1730,
GT1582, GT1588, PS104, RL2002, SD1500 and
raw materials: 58 (DEEA), 801, 863, 872, 1168, 1201, 1490(hydrochloric acid), 1341 (calcium ammonium nitrate, nitric acid), 2040, 2052, 2057, 2068, 2072, 2077, 2084, 2086, 2088, and potassium permanganate.
The order quantity is excessive for normal water treatment use. / YES___NO_X_
The ordering contact requested excessive confidentiality concerning delivery final destination. / YES___NO_X_
The ordering contact does not want to provide end use information. / YES___NO_X_
Answer the questions below for equipment orders:
Equipment requested to be lined with nickel, hastelloy, monel and other high nickel content which are airtight beyond the normal requirements for water treatment applications, especially when less expensive models are appropriate for the end use. / YES___NO_X_
Customer’s order is for parts known to be inappropriate, for which the customer appears to have no legitimate need (e.g., open top tanks, or there is no indication of prior authorized shipment for this type of equipment, e.g. vacuum pump or a microwave). / YES___NO_X_

Reference: BIS’s “Know Your Customer” Guidance at: