The Federal Bureau of Investigation (FBI) has produced some excellent literature to help corporations and research institutions avoid the pitfalls of deemed export violations. Their current pamphlet outlines the potential perils of welcoming foreign visitors.
From a deemed export compliance standpoint, preparing for foreign visitors requires significant attention to detail and company-wide understanding of how to protect your technology, research, blueprints and any other sensitive items. And once you’ve taken steps to train staff on visitor protocol, perform Restricted Party Screening (also known as Denied Party Screening) on potential guests, develop a technology control plan, acquire the correct licenses for your technology, etc., it’s important to understand that your work isn’t quite done. The FBI reminds us that even once your approved visitors are standing in your approved visitor areas observing your approved technology, you can’t let your guard down.
Requests or gains access to an area that is beyond the scope of their visit. Like the houseguest that just has to know what’s in your medicine cabinet, a visitor with ill-intent may try to see more than you’re prepared to share. Be wary if your visitor appears just a little too curious.
Takes photographs or keeps security identification badge. Nobody is that sentimental. If your visitor wants a memento of the good times you’ve shared, perhaps a company pen would be a better choice.
Continually forgetting security protocols or need to be reminded “You can’t do that.” If your visitor seems terribly absent-minded when it comes to the requirements he/she has agreed to and signed off on, there may be more going on than meets the eye.
Asks questions about programs using acronyms specific to the program that they should not necessarily know about. Maybe your guest is particularly observant and a quick study. Or maybe your guest has done a lot more homework about your organization than you realize.
The FBI advises that if you do notice any suspicious behavior or activity, don’t second guess your judgment. Report the activity to your security officer immediately, and let the security officer be the one to determine if an incident is harmless. You’ve nothing to lose but everything to protect.