An often-overlooked opportunity for compliance professionals and empowered officials is an on-site visit at a potential client or supply chain partner’s facility. While these visits are usually choreographed to highlight the strengths of the company, they also provide an opportunity to see the ground truth behind the operation. While conducting end-use verifications for the Bureau of Industry and Security during my career there as a Special Agent, I developed a strategy that allows the guest to evaluate an operation regardless of the dog-and-pony show elements that often accompany a planned visit.

There are things to consider about the timing of a site visit. Most visits by invitation of the host or requests initiated by the visitor well in advance will often be well-planned to highlight the positive and obscure the negative. An unannounced visit precludes this but may limit staff availability or access to a work floor or other sensitive site that might be available with a planned visit. When I conducted end-use verification visits for BIS, I always made an appointment but tried to keep it to a few days or a week if possible. It gives enough time to ensure a good tour but not enough to make significant material changes to hide problems.

The first A of the visit is Arrival. You should think about the visit starting when you can see the building or campus: what is the approach road like – could you visit unannounced, or will they see you coming? What is the perimeter security like, if any, and how does that security compare with the neighbors? How’s the parking situation? Parking is an important factor, especially if it is raining and you do not have an umbrella. But personal comfort aside, knowing if the facility has dedicated parking means you can monitor activity; if they say they only run one shift, but cars are filling the lot 24/7, you may want to ask some questions about that.

The next A is for access control, and here’s where I have to confess that as a test of security, I would do something I’m not proud of. It always annoyed me when people felt entitled to bypass routine screening or identification procedures, but when I approached, I always expected the guard to wave me by. Secretly, I would be relieved when the person told me I needed to wait and produce government-issued identification. But I’d still try to pull the “do you know who I am” bit anyway. If they let me slide, who else could strong-arm their way in and avoid screening?

Activities is our next A, which refers to observing what is being shown to you and, more importantly, what is happening around you. Like a kid in a candy store, I’d be scanning the rooms and hallways, not knowing what I’d find but noting everything I could recognize. What does that door lead to? Why did our guide have to swipe in at the first doorway but not further inside? Where are most of the workers located – do they all look busy? A basic knowledge of the business helps here – especially if you’ve visited similar facilities in the past, you’ll be able to recognize outliers and construct good questions regarding the process and any security factors you might be concerned about.

Awareness is an important but often overlooked A. By awareness, I am referring to how aware the employees and staff are of their responsibilities regarding compliance. Are there posters for “whistleblower” programs that include strategic trade controls? Does the guard or receptionist screen visitors for nationality and sanctions issues? If you have the opportunity to speak with a person on the work floor or in a corridor who is not part of your host team, are they aware of compliance issues and how to report a problem? The good news is, if everybody was prepared in advance to tell you how important they take compliance, they are either being honest or exhibiting knowledge for the purpose of prosecution. I prefer the former today but always sought the latter in my government days.

Our final A stands for the Actors. As the bard said, “All the world’s a stage,” and the actors are what brings the show to life. We’ll start with the folks guiding your tour or sitting in your meetings: they are your leading actors – remember that they are probably well-scripted. This is not a nefarious thing: they should be prepared to answer your questions and tout the strengths of their work. Everyone wants to put their best foot forward in these situations, and you should listen intently for clues to their sincerity. Ask a follow-up if a thoughtful question is answered with a canned response. If you think you’re being sold a story, you probably are. Good follow-ups will confirm facts or at least get you closer to the hard truth. But don’t forget the bit players: if you are lucky, you will be able to speak with line employees, other visitors, or even clients. Get their observations, ask them about their experiences with the company and the facility, and never underestimate the knowledge of the staff and the value of the off-the-cuff conversation.

It takes time and experience to master the art of the site visit truly. But the good news is we can help! By bringing Torres Trade in to accompany you, we can prepare you before the event with information collected through our proprietary due diligence research process, apply our deep knowledge of international trade regulations and procedures, and put the years of experience our staff has right next to you as we walk through the door. I’ll even bring an umbrella, just in case it rains.