Direct answer: a red flag is an abnormal fact indicating possible export-control risk. It does not automatically prove a violation, but it should trigger a pause, escalation, evidence-based review and a documented decision.

Customer & counterparty (8)

  1. The customer is unwilling to provide detailed end-use information
  2. The customer's name resembles, or is known to be linked to, a sanctioned entity
  3. Requests for cash, third-party payment, or otherwise unusual payment methods
  4. A newly formed company registered at a virtual office
  5. No interest in installation, maintenance or training for the product
  6. Refuses to provide company registration or to sign an end-use statement
  7. Deals through multiple middlemen of unknown origin
  8. The beneficial owner or shareholders are from a sanctioned country

Product & order (6)

  1. The item ordered does not match the customer's normal business (a bakery buying precision instruments)
  2. Requests for non-standard configuration or special modification
  3. Requests to remove nameplates, labels or model identifiers
  4. Order quantity clearly exceeds reasonable need for the business's scale
  5. Requests for non-standard packaging or labelling
  6. Refusal of normal after-sales service or training

Shipping & logistics (4)

  1. An uneconomic or illogical route (detour through a third country, then transship)
  2. Requests to ship to a third-country address unrelated to the destination
  3. Delivery timing inconsistent with a normal commercial cycle — extreme urgency
  4. The customer arranges shipping itself and the carrier's information is opaque

Technology & R&D (3)

  1. Foreign personnel request access to controlled-technology labs (deemed export)
  2. In international cooperation, the other side demands "all technical data"
  3. A foreign customer requests technical documentation beyond normal commercial need

Standard operating procedure

Red flag detected
  → Pause the transaction immediately
  → Report to the compliance owner
  → Investigate (customer / end-use / destination)
     ├─ Doubts cleared → proceed (record the process and conclusion)
     └─ Cannot be cleared → refuse, or apply for a licence

Print this list and post it at the sales and documentation desks — red-flag recognition is everyone's job, not one department's. Our training service includes industry-tailored red-flag scenario drills.