Export Compliance

International Hiring: Denied Party Screening one of FIVE Deemed Export Compliance steps to find out who’s behind that resume

Anyone who’s ever been responsible for hiring knows all too well that a resume doesn’t always tell the full story about a potential candidate.

Applications peppered with inflated education and creative job titles (“Yes, I was a manager – I managed our weekly potluck lunch for five years”) is par for the course when you’re in Human Resources.

But while lying on a resume is wrong for a host of ethical and professional reasons, export compliance professionals have particular reason to be concerned about lies when the applicants are international workers. When it comes to deemed export compliance, it’s not only what these workers say on their resumes, it’s what they don’t say that could be a problem. While Denied or Restricted Party Screening is a critical part of the HR compliance process, there are other steps that should be followed.

Facilities that deal with controlled items or technology must be particularly mindful of export compliance considerations when hiring foreign workers.  If they’re not, they’re at risk of illegally sharing restricted information with unauthorized persons. This is considered a deemed export violation, and corporations and research facilities with even the best of intentions have lost millions of dollars (and had their reputations damaged) because of them. The problems can start with candidates who look perfect on paper but who have omitted some very critical facts from their resumes.  A history of working on weapon system research, an affiliation with foreign militaries or a contract in an embargoed nation  are just a few example of what has been conveniently omitted from some work histories.  This is all information that companies need to know before hiring people to work with sensitive equipment, software, biological agents or other restricted items.

It is not always possible to determine whether or not a resume contains falsehoods or omissions that could put your corporation or research facility at risk. When hiring international employees, it is vital to:

  • Denied/Restricted Party Screening. This is a must. You’ll not only find out whether or not the name you’ve been given appears on any sanctioned or denied party list, but you’ll also be more likely to uncover aliases.
  • Check references. It’s worth the time and effort. Asking a reference questions about your candidate’s periods of employment, responsibilities and even the location of a previous employer can help you be certain the facts of your candidate’s story are true.
  • Do your research. Not sure about a foreign-based company? Do some Googling to find out more.
  • Ask around. If you’re a research facility, you know that the university community is a small one. You may be surprised by what others know about your applicant.
  • Resist the urge to cut corners. It may be tempting to quickly welcome a talented individual so that you can get projects off the ground, use up a vanishing budget or simply avoid some red tape.  But while ignoring the reality of license requirements (both for workers and for the controlled technology to which they may be exposed) and security clearances may save you time in the short-term, it could be a source of tremendous regret down the road.

The range of experience and talent an international worker can bring to the table is worth the bureaucracy it entails. And a little extra precaution can help you ensure you’re getting the employee you’ve bargained for.