What happens if my customer reexports or transfers a License Exception STA-eligible item without first obtaining a prior consignee statement?

Any reexport or transfer of an item under License Exception STA without obtaining and maintaining a prior consignee statement is a violation of the EAR. BIS routinely conducts end-use checks on items authorized for export under STA and will request the foreign party to produce a copy of a prior consignee statement if the item was subsequently reexported or transferred under License Exception STA. If the foreign party cannot provide such documentation, the foreign person may be subject to BIS enforcement action.