Disregard of International Trade Restrictions

An internal review of inventory at a global manufacturing company revealed that product manufactured in one country was delivered to customers in another country in violation of trade restrictions. Axium was engaged to investigate how the violation occurred despite controls specifically designed to prevent this type of violation. We conducted an extensive review of email data of employees involved in the internal distribution of product from multiple manufacturing facilities. We also analyzed accounting records, as well as shipping and import documentation. Axium interviewed employees in five countries to gain an understanding of the processes, controls, and violations. We found that, in order to meet pressing customer demands for product, certain employees disregarded established controls of product distribution. We also found that these employees took steps to minimize the risk that their circumvention of the controls would be detected.