WE can train you in import export procedures (company).
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
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.
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.
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.
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.
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.
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)
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.
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
CLASSIFICATION Best way is to have the HTS Index. Search with term and see if it is listed. Refer to the referenced HTS number(s). Apply the GRIs. GRI 1 will be applicable most of instances…but follow the other GRIs as applicable.
Retired FNIS Maready instructed on classification in Southeast U.s. Retired FNIS Key also taught. We are not the best but in that class. We can make you better and cut through the clutter.
We can coach you in this field. Our experience and tools afford you opportunity to excel. Support tools and experience is available to make you more than successful. You can improve skills in CLASSIFICATION and VALUATION ECCN . Master EAR Regulations, and establish/improve Export Compliance Manual. We can help in training and establishing internal training as well as internal audit.
All subject matter is supported by references including Customs Broker Exams which support classification and valuation..
We can meet with you to discuss and demonstrate at your facility and support by distance through gotomeeting computer dialog. Not only coach but mentor as well.
704 664 1932 Clement Key (2 retired Customs Field National Import Specialists available)
EXPORT COMPLIANCE POINTS
Dedicated 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.
Executive involvement. Recommended BIS ( & CBP) compliance recommends executive involvement to make compliance work.
Written Manual. Again a BIS (CBP) recommended point.
Internal control reviews. BIS point in recommended compliance program. Without reviews it is hard to detect where to make improvements/adjustments/accountability.
Training programs. BIS point. Having ongoing training indicates seriousness of compliance.BIS compliance
Convey compliance requirements to/for suppliers. Communication with suppliers can reduce risks and increase compliance.
Record-keeping program. BIS point. Mandatory by CBP. Necessary for internal audit and regulatory audit.
C-TPAT-CBP. Involvement with the program and maintaining information lines with agencies assist in compliance.
Risk Assessment. BIS point – Evaluate vulnerabilities and provide resources to address.