import export compliance training

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

 

ITAR technology export violation

ITAR compliance risks

Unauthorized exports included the transfer of technical data

Significant improvements to its export compliance program that reduce the likelihood of future violations, including conducting internal and independent audits, conducting staff training on the ITAR (including more extensive training for personnel directly involved in export compliance), creating a fully documented compliance program (with formal procedures, checklists, and a compliance manual), and significantly increasing staff resources devoted to day-to-day compliance (including retaining an outside consultant to provide expert advice where needed). These steps were taken after the fact and should have been in place to prevent.

Posting drawings on website or sending to foreign supplier for quote can constitute an export without a license and bring penalties. Bright Lights USA

https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=715d7289db99db0044f9ff621f961939

training tutorial

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

ITAR training points

Three areas of export control laws. The International Traffic in Arms Regulations or ITAR, which is administered by the State Department. These apply to military products. The Export Administration Regulations or EAR, administered by the Commerce Department. These apply to commercial products that have some use in the military or intelligence area and the U.S. Sanctions Laws, administered by the Treasury Department’s Office of Foreign Assets Control.

The first cornerstone concept under ITAR – ITAR contains a list of products called the U. S. Munitions List (USML) If your product is on this list, it is subject to these controls. This is a key concept. If your product is on the list, everything else flows from this. If you look down the list, you will see that the majority of headings- a lot of the items in the beginning of the list are truly defense items: firearms, guns, explosives, naval vessels. But, if you look farther down the list, you will see that the categories start to overlap with commercial items – training, electronics, chemicals, satellites. So it is sometimes difficult to determine if your product is on the list or not

Another cornerstone concept is that these controls apply not just to physical products, but also to software and technical data, as well. So, if an item is on the list such as a navigational device – the software used to run that device is also on the list, and the technical data related to the device is on the list. Technical data refers to drawings, algorithms, manuals, any information on the design, manufacture, or use of the item. So, if the product is on the list, then the electronic files are on the list, the specification sheets, the technical manuals – are all on the Munitions List and subject to ITAR.

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