Skyway is a Connecticut-based distributor of aircraft spare parts. A few of their products are subject to the Commerce Control Lists (CCL) as they are

Skyway is a Connecticut-based distributor of aircraft spare parts. A few of their products are subject to the Commerce Control Lists (CCL) as they are considered “dual use” items and are subject to export control regulations. Debra Bright, the salesperson, receives a faxed request from a potential new customer, Trois Avion, located in Paris. The fax contains a request for an order of XKY2. XKY2 is one of the products distributed by Skyway that is listed on the CCL. The order is a high value order and the biggest order Debra has ever received in three years of working with Skyway. Debra processes the quotation and sends the standard documents by fax to Trois Avion. These documents include a credit application and an end-use statement by Trois Avion. Trois Avion accepts the quotation, returns the credit application, and requests for the order to be shipped immediately. Debra grows concerned that the quantity requested is a large order for Skyway and they may not be able to process the order on a timely basis. Debra contacts Trois Avion by phone and speaks with Monsieur Jacque Gaspar. Monsieur Gaspar understands this is a large order and offers to pay cash to expedite the order. Debra arranges to accept the wire transfer of funds on behalf of the company and waives the credit application. She contacts her warehouse manager and begins to coordinate the materials for shipment. Debra advises Monsieur Gaspar the order will be processed within the requested time frame. At this time, Debra advises Monsieur Gaspar that Skyway has a field engineer working another job in France and that the field engineer can be scheduled to demonstrate the installation of the parts to Trois Avion personnel. Monsieur Gaspar informs Debra that Trois Avion is declining the field training. Monsieur Gaspar faxes Debra a letter of instruction. The destination address is for a freight forwarder located in Paris, France. There is also a notation on the letter of instruction to include installation instructions in Arabic. Debra calls Monsieur Gaspar to advise instructions in Arabic are not available and hopes this is not a problem. Monsieur Garspar advises the shipment should just ship out as instructed and not to be concerned about the instructions. Debra receives a call that the order will be ready to ship on Thursday afternoon. Debra confirms that accounting has received the payment for the shipment. Debra is anxious for the order to ship as she is scheduled to leave for a long planned vacation in Las Vegas on Friday morning. This sale has also put Debra into the “Silver Sales Group,” entitling her to a substantial bonus. On Friday morning Debra contacts her shipping department and is advised that the order was picked up by Skyway’s freight forwarder and will be shipped on a flight on Friday evening. Debra instructs her shipping department to forward the flight information to Trois Avion. Debra phones Monsieur Gaspar to advise everything is moving on schedule. Debra is relieved the shipment is moving and departs on her flight to Las Vegas. On Friday afternoon, the airline carrier contacts Skyway’s forwarder to advise the export that the shipment has been seized by Exodus, which is the export enforcement arm of Customs. The Bureau of Industry & Security (BIS) has listed Trois Avion as a Denied Person. On Monday morning, an officer from the BIS is waiting to meet with senior management at Skyway. The BIS officer requests to see the export transaction filed for the XKY2 order and a copy of the export compliance procedures for Skyway. The senior manager at Skyway is only able to produce a copy of the faxes Debra sent and received from Monsieur Gaspar. Clearly missing from the file are a copy of the denied party screening, end-use statement, export license, and any conversations regarding the various red flags that should have been raised within the transaction dialogue. Skyway pays civil penalties of $35,000 and is denied export privileges for one year. As part of their settlement, Skyway is required to spend an additional $15,000 in implementing an export compliance program including training to prevent future incidents. Upon Debra’s return from vacation, she is seeking employment elsewhere, but not in the aircraft industry. (At least 3 scholarly sources must be referenced in APA format) Purchase the answer to view it

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