WHAT.4 EU Sanctions DD

EU Sanctions DD WHAT.4: Customer Technical Competence Assessment

What This Control Requires

Does the customer demonstrate genuine technical knowledge of the product or service they are purchasing?

In Plain Language

A customer who is unfamiliar with product specifications yet insistent on purchasing specific items is a documented EU red flag. It suggests they may be procuring on behalf of someone else - potentially a sanctioned party who cannot buy directly.

The EU Sanctions Compliance Helpdesk identifies this pattern: a buyer who cannot explain the intended use, lacks technical staff for a technically complex product, insists on specific models or configurations without understanding the specifications, and shows disinterest in training or after-sales support.

This is particularly relevant for dual-use goods and advanced technology where legitimate buyers typically have detailed technical requirements and ask informed questions during the sales process.

How to Implement

During the sales process, assess whether the customer understands what they are buying and why. This should be part of normal commercial engagement, not a separate interrogation.

Red flags to watch for: - Inability to explain the intended use or application of the product - Lack of technical staff for a product that requires expertise to operate or integrate - Insistence on specific models or configurations without understanding the specifications - Disinterest in training, technical support, installation assistance, or maintenance contracts - Declining standard product demonstrations or technical consultations - Purchasing products that do not match their stated industry or business profile - Ordering unusual quantities - either much more or much less than typical for the stated application

Document customer interactions during the sales process. Train sales engineers and account managers to recognise and escalate these indicators.

This assessment is most important for controlled items, dual-use goods, and high-value technical products. For commodity products, the assessment can be lighter touch but should still flag obvious mismatches.

Evidence Your Auditor Will Request

Sales interaction records documenting customer's technical engagement and knowledge level
Training records for sales staff on recognising procurement red flags
Escalation records for cases where customer technical competence was questioned
Customer visit or communication records showing technical discussions
Documentation of any transactions declined or escalated due to competence concerns

Common Mistakes

Sales teams focused solely on closing deals without considering sanctions red flags
No structured process for assessing customer technical competence during the sales cycle
Failing to train sales engineers and account managers on procurement red flags
Not documenting customer interactions that could reveal competence concerns
Treating all customers the same regardless of risk profile or product sensitivity

Related Controls Across Frameworks

Framework	Control ID	Relationship
EU Sanctions DD	EU Sanctions DD WHAT.1 (related mapping)	Related
EU Sanctions DD	EU Sanctions DD WHY.1 (related mapping)	Related
EU Sanctions DD	EU Sanctions DD WHY.4 (related mapping)	Related

Frequently Asked Questions

How do we assess technical competence without offending the customer?

Frame it as good customer service, not interrogation. Ask about their application, requirements, and integration needs as part of normal solution selling. Offer technical consultations, demonstrations, and training. A legitimate customer will welcome this engagement. A front buyer will typically try to minimise interaction and just wants to complete the purchase. The assessment happens naturally through normal commercial engagement.

Does this apply to all products or only controlled items?

The assessment is most important for controlled and dual-use items, advanced technology, and high-value equipment. For commodity products (office supplies, standard consumer goods), a lighter touch is appropriate. However, even for seemingly innocuous products, be alert to orders that do not match the buyer's profile - a bakery ordering large quantities of electronic components should raise questions regardless of whether the components are controlled.

What if the buyer uses a procurement agent?

The use of procurement agents is common in international trade and not inherently suspicious. However, if the agent cannot provide information about the end-user's technical requirements, refuses to disclose the end-user identity, or insists on managing all technical communications, these are additional red flags. Request direct contact with the end-user's technical team for significant transactions involving controlled or sensitive products.

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