Is an AES filer responsible for the accuracy and completeness of the EEI when relying on information from others?

The assertion that an AES filer is not responsible for the accuracy and completeness of the Electronic Export Information (EEI) when relying on information from others accurately reflects the responsibilities defined in export compliance regulations. The primary responsibility for submitting accurate and complete EEI rests with the individual or entity that is filing the AES.

While filers may use information provided by other parties, such as suppliers or freight forwarders, they must ensure that the data submitted is correct. However, they are not held liable for inaccuracies in the information sourced from outside parties, provided they exercised reasonable care in verifying such data. This aligns with the regulatory perspective that emphasizes the importance of due diligence while allowing for reliance on external information.

It’s crucial for AES filers to have robust processes in place for information verification to minimize compliance risks and ensure that the submission is as accurate as possible. While this reliance is permitted, it underscores the importance of proper vetting and validation practices within the export documentation process.