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Safe, unsafe, or in between? How to really know your customer
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When: Wednesday, January 22, 2020
7:30 am – 12:00 pm
Where: The Wilds Golf Club
3151 Wilds Ridge Ct
Prior Lake, Minnesota  55372
United States
Contact: Adam Palmer

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Note: Participants should bring their laptops to complete hands-on exercises.

Program Description

This workshop focuses on the seemingly simple export guidance of “know your customer.” It addresses the challenge of how to identify whether you have taken effective steps and have acquired enough information to really know your customer. This is not just for the easy ends of the spectrum — clearly safe or un-safe customers — but those somewhere in-between that pose the greatest challenge to arriving at a decision whether to proceed.

Using real-life case facts and scenarios as a guide, this workshop will help you understand the regulatory requirements and gain practical knowledge, skills, and best practices you can apply to your compliance program. Participants will benefit from hands-on reviews and follow-up discussions of practice fact scenarios.

Moderated by Ann Thomas, an experienced export consultant, the workshop includes the perspectives of enforcement experts from three key government agencies: Homeland Security Investigation (HSI), Bureau of Industry and Security (BIS), and the Federal Bureau of Investigation (FBI). Agency representatives will share the experience and insight they gained first-hand through their efforts to prevent bad actors from diverting, obtaining, or misusing U.S. materials and technology. You will also have the opportunity to learn about agency resources to support your compliance program and pose questions to the experts.

The goal is to assist program owners and practitioners to better identify and moderate risk and be able to respond quickly and effectively to potential concerns. A sample of topics include identifying and addressing red flags, avoiding self-blinding, implications of end-user and end-use controls, the intersection with OFAC sanctions, and documentation and recordkeeping.

Who Should Attend

  • Trade Compliance Professionals
  • Trade / Export Specialists
  • Trade Program Stakeholders
  • Logistics
  • Legal Counsel / staff
  • Sales Staff
  • Customer Service

Learning Objectives

  1. Understand the knowledge standard behind “know your customer”
  2. How to identify and resolve red flags and above self-blinding
  3. Understand intersection with OFAC sanction programs
  4. How to maintain recordkeeping best practices
  5. How to respond quickly if needed – when to escalate, when to seek enhanced due diligence
  6. Considerations to establish effective policies and procedures


Ann Thomas — President, Circinus, Ltd.

Ann Thomas is the President of Circinus, Ltd., a company that specializes in import and export compliance consulting. Ann has more than 25 years of experience in trade compliance and international trade issues with Circinus and in her previous positions with manufacturing companies. Ann holds a Bachelor of Science in Business degree from the University of Minnesota and earned a Master of International Management degree from the University of St. Thomas in St. Paul, Minnesota. She is also a licensed U.S. customs broker and maintains the designation of Certified Customs Specialist from the National Customs Brokers & Forwarders Association of America’s Educational Institute. Ann is a past president of the Minnesota World Trade Association (now the MGTA), a charter member of the Twin Cities Import/Export Council, and a member of the MGTA, the NCBFAA, and the International Compliance Professionals Association.

Homeland Security Investigation (HSI) Representative

Homeland Security Investigation (HSI) Counterproliferation Investigations works closely with other Federal law enforcement agencies to prevent illicit procurement networks, terrorist groups and hostile nations from illegally obtaining United States military products, sensitive dual-use technology, weapons of mass destruction, or chemical, biological, radiological and nuclear materials.

HSI employs a wide variety of enforcement authorities in deterring, disrupting and dismantling transnational criminal networks. HSI uses its full statutory authority to investigate criminal export violations and enforce all U.S. export laws related to military items, controlled “dual-use” commodities and sanctioned or embargoed countries and outbound smuggling.

Bureau of Industry and Security (BIS) Representative

Bureau of Industry and Security (BIS) is the principal agency involved in the development, implementation, and enforcement of export controls for commercial technologies and for many military technologies as a result of the President’s export control reform initiative.

Federal Bureau of Investigation (FBI) Representative

The FBI through its Counterproliferation Center (CPC) works closely with other U.S. government agencies including the Department of Commerce’s Office of Export Enforcement and the Department of Homeland Security’s Homeland Security Investigations to fulfill its mission of leading the FBI’s efforts to identify, deny, disrupt, and exploit attempts to obtain or divert embargoed, export-controlled, or otherwise sensitive technologies or activities related to WMD (chemical, biological, radiological, nuclear, or explosive), missile delivery systems, space or conventional weapons systems, or dual-use components. CPC personnel also work to identify critical intelligence gaps in the current threat environment, look at proliferation threats emerging on the horizon, and develop strategies to ensure that the FBI continues to be well-positioned to address the counterproliferation threats of today and tomorrow.


7:30 a.m. Registration, breakfast and networking
8:00 a.m. Program
9:30 a.m. Break
9:45 a.m. Program
10:45 a.m. Break
11:00 a.m. Program
12:00 p.m. Adjourn

Registration Fee

Members — $75
Non-members — $100
Students — $15

PCI Compliance: MGTA has taken the appropriate steps to maintain PCI compliance. In order to protect your privacy, please do not email your credit card information to our office.

Cancellation Policy: With written cancellation notice, received at least 1 week prior to the event, you will receive a full refund, minus a $10 administrative fee. No-shows will not receive refunds.

Audio/Video Policy: Registration and attendance at, or participation at association events constitutes an agreement by the registrant to association’s use and distribution of the registrant or attendee’s image or voice in photographs, videotapes, electronic reproductions and audiotapes of such events and activities.

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