export compliance

The Economist August 2014 reported in an article The Criminalisation of American Business that settlement of Import/Export sanctions led all others by a great amount of settlement dollars (major lead by @ 3 times collective others). The other settlements being Antitrust, Bank Secrecy Act, Environmental, Bribery, Fraud, Pharma, Securities Fraud. This means that importers and exporters are in the crosshair of targets for penalty action. This translates to a need for better compliance in these activities. Either take the responsibility or face legal fees and or penalties.

A good compliance program in import and export requires that you show training and self audit or external activities in these areas. There is more to it but these are important.

The following represent bare essential elements:
9 point guide to compliance
1. Whether the company has performed a meaningful risk analysis.

2. The existence of a formal written compliance program.

3. Whether appropriate senior organizational officials are responsible for
overseeing the import compliance program.

4. Whether adequate training is provided to employees.

5. Whether the company adequately screens its customers and transactions.

6. Whether the company meets recordkeeping requirements.

7. The existence and operation of an internal system for reporting import
violations.

8. The existence and result of internal/external reviews or audits.

9. Whether remedial activity has been taken in response to import
violations.