One factor in a sound import compliance manual is conducting an internal import audit and /or external import audit records. You really need to monitor the soundness of your compliance by conducting import internal audits of your activities and taking necessary corrective actions. Import audit training is important. Import training is important.
Important for import compliance and import audit training. Import internal audit is important factor in import compliance manual.
Check out this book and add to your compliance references.
Import Compliance Manuals, Export Compliance Manuals
9 Factors for Import or Export Compliance Part 3
3rd factor of 9
3. Whether appropriate senior organizational officials are responsible for
overseeing the import compliance program.
There must be involvement from officers to show that they stand behind the compliance program and to lend support as well as necessary resources. Compliance will be weak without their involvement.
In the U.S. vs. TREK Leather case ruling, Reasonable Care is hard to define BUT the prudent business man rule is very relevant. If you are in the import export business then exercise such care as required. Have a import compliance manual and export compliance manual as activity warrants. Those manuals should address 9 factors:
Perform a Meaningful Import / Export risk analysis.
Have a formal written import / Export compliance program!
An officer must be responsible for overseeing the import / Export compliance program.
Adequate training must be provided for employees.
A company must adequately screen their customers and transactions.
Your company must meet the compliance program’s record keeping requirements.
The existence and operation of an internal audit system for reporting Import / Export violations must be in place.
Your company must keep on file the documented results of internal / External reviews or audits.
Proof of remedial activity that has been taken in response to import / Export violations