Import and/or Export Controls Training

TRAIN Employee for import and/or export compliance function

Call to discuss and to schedule “gotomeeting” content demo. Fill internally!

Clement Key
"import/export consulting" >>>>>> TRAINING
336 E Cedar St
Mooresville, NC 28115
704 664 1932

Train your selected person to fill import/export position!

We can assist your meeting following:

  1. Dedicated customs group or leader with knowledge. This will help define corporate compliance, provide oversight to operations related to compliance, and provide coordination with different departments—including warehousing, purchasing, and logistics—involved in compliance.
  2. Executive involvement. Recommended BIS ( & CBP) compliance recommends executive involvement to make compliance work.
  3. Written Manual. Again a BIS (CBP) recommended point.
  4. Internal control reviews. BIS point in recommended compliance program. Without reviews it is hard to detect where to make improvements/adjustments/accountability.
  5. Training programs. BIS point. Having ongoing training indicates seriousness of compliance.
  6. Convey compliance requirements to/for suppliers. Communication with suppliers can reduce risks and increase compliance.
  7. Record-keeping program. BIS point. Mandatory by CBP. Necessary for internal audit and regulatory audit.
  8. C-TPAT-CBP. Involvement with the program and maintaining information lines with agencies assist in compliance.
  9. Risk Assessment. BIS point – ID vulnerabilities and provide resources to address.

Compliance manual. BIS points – Serves as standard and must be effective.

IMPORTANT Enforcement Keynote Address Assistant Secretary Darryl W. Jackson
BIS Export Control Forum 2008 Newport Beach, CA March 17, 2008 - applies to Import Ops also

There is no "one size fits all" compliance program. But, to be effective, all export compliance programs, no matter how large or small the company, no matter how simple or complex the business, will evidence the following nine principles. Those principles must appear in the design of the program and they also must be actually implemented. Put differently, it is difficult to implement that which is not in the design of a plan. But conversely, merely having a well-designed compliance plan is not enough, the plan also must be operational.
Here are the nine principles we apply in deciding whether a compliance program is effective and entitled to great weight mitigation. Following adapted from advice on export controls…same points apply to IMPORT.

BIS recommendations for compliance

  1. Whether the company has performed a meaningful risk analysis.
    You conduct risk analyses in other aspects of your business, and you must do so in fashioning an effective compliance program as well. A meaningful risk analysis is the baseline from which an effective compliance program is designed. Among other things, you must consider the types of goods you are importing
  2. The existence of a formal written compliance program.
    Without a written compliance program, there is no baseline from which to measure its effectiveness. There are no common goals set or communicated to others for the program.
  3. Whether appropriate senior organizational officials are responsible for overseeing the import compliance program.
    Put people at a high level of responsibility into oversight positions for this and all other import-related matters. Please, do not leave these important issues to some isolated, lower-level person in the company. That is not the way companies deal with important issues.
  4. Whether adequate training is provided to employees.
    You will have to train your employees so that they know what is required of them to be in compliance. For them to stay abreast of developments, the training will have to be ongoing. In order to hold them accountable, you will have to maintain records showing that you provided appropriate training.
  5. Whether the company adequately screens its customers and transactions.
    Your program has to have put the proper controls in place, including the various import screening mechanisms. On BIS’s website, you will find "Know Your Customer" guidance, and the various lists against which you should screen import/export transactions.
  6. Whether the company meets recordkeeping requirements.
    CBP&BIS have recordkeeping requirements, and you should make sure that you meet them. You should also maintain the kinds of records commonly expected in your line of business, all of which properly document the transactions in which you have engaged.
  7. The existence and operation of an internal system for reporting import violations.
    Your compliance program should have an internal system through which employees can report suspected import violations. Such reporting systems provide you with the ability to look into such matters further and take appropriate action, including making Voluntary Self-Disclosures (PRIOR DISCLOSURE Customs Regulations 162.74)
  8. The existence and result of internal/external reviews or audits.
    You will have to test your program by running periodic audits of some kind, which will show you how well it is working. You will have to modify your procedures in light of what those audits show. Moreover, you will need to review, revise and update your compliance programs. If you have not taken a look at your program recently, it is probably time to do so. And it is probably time to revise it, in light of recent developments that have occurred in the law, in business and elsewhere.
  9. Whether remedial activity has been taken in response to import violations. Under your compliance plan, it is important that you take appropriate disciplinary actions against employees who put you at risk not merely sweep those problems under the rug. Meeting Your Burden for Great Weight Mitigation