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.
Internal training is important! BIS recommended compliance point
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.
our tools and gotomeeting can answer your training needs and help you provide internal training to your employees.
Import Compliance Manuals, Export Compliance Manuals
9 Factors for Import or Export Compliance Part 2
2. The existence of a formal written compliance program.
From sentencing guidelines insight on effective import export manual standard
8B2.1. Effective Compliance and Ethics Program
(a) To have an effective compliance and ethics program, for purposes of subsection (f) of §8C2.5 (Culpability Score) and subsection (c)(1) of §8D1.4 (Recommended Conditions of Probation – Organizations), an organization shall—
(1) exercise due diligence to prevent and detect criminal conduct; and
(2) otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.
Such compliance and ethics program shall be reasonably designed, implemented, and enforced so that the program is generally effective in preventing and detecting criminal conduct. The failure to prevent or detect the instant offense does not necessarily mean that the program is not generally effective in preventing and detecting criminal conduct.
(b) Due diligence and the promotion of an organizational culture that encourages ethical conduct and a commitment to compliance with the law within the meaning of subsection (a) minimally require the following:
(1) The organization shall establish standards and procedures to prevent and detect criminal conduct.
(2) (A) The organization’s governing authority shall be knowledgeable about the content and operation of the compliance and ethics program and shall exercise reasonable oversight with respect to the implementation and effectiveness of the compliance and ethics program.