import export compliance training

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http://www.exportimportcompliance.com/controls-training.php

WE can train you in import export procedures (company).

  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

 

ITAT compliance manual training control

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EXPOSURE to ITAR Compliance failure is highly probable if you do not have an effective manual and adherence to the following factors.

Without management participation, reviews, training and monitoring = failure. 

Export (ship) – send abroad

Go abroad and release information – overseas speech

Allow access to product or information with foreign national – private conversation

Electronic transmission 

Factors to consider in a strong compliance system.

  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 export ITAR 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 export ITAR violations.
  8. The existence and result of internal/external reviews or audits.
  9. Whether remedial activity has been taken in response to export ITAR violations.

Set up training and audit using our materials.

exportimportcompliance.com

ITAR Compliance Manual and effective control

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https://www.pmddtc.state.gov/compliance?id=ddtc_kb_article_page&sys_id=384b968adb3cd30044f9ff621f961941

FLIR case

ITAR Compliance Program failure (s)

Significant compliance program and internal control deficiencies that directly contributed to the violations.

Deficient ITAR expertise and senior leader oversight during violation period.

Failure to effectively investigate and discover uncover and disclose violations.

Frequency and repetitive nature of same violations.

Failure to implement remedial compliance measures represented to the department.

Need to have an effective compliance program and effective administration including review.

Avoid penalties ($30,000,000) and controls by having effective control.

Factors to consider in a strong compliance system.

  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 export 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 export violations.
  8. The existence and result of internal/external reviews or audits.
  9. Whether remedial activity has been taken in response to export violations.

https://www.sbir.gov/tutorials/itar/tutorial-1#