Clients often know that they need help with export compliance but don’t know where to start. This info, from a previous post, should help. A well written and maintained EMCP is the ideal way to keep compliant. However, an EMCP is costly and time consuming. Because there is considerable risk in being non-compliant, don’t make the mistake of doing nothing because you are not in a position to implement an EMCP. You can, and should, take some basic steps.
Implementing a formal Export Management Compliance Program can be quite intimidating especially for small and medium sized companies. An EMCP requires a significant commitment of time on the part of management and usually involves hiring an outside consultant for the initial set up. There is no question that a written EMCP is a good investment for any company to make. An EMCP establishes clear accountability, written instructions, and reduces risk of non compliance. If the exporter has not experienced problems or incurred any fines it is easy to make an EMCP a “back burner” issue. If your company has not implemented an EMCP it is still good business practice to take some basic compliance steps. While these steps cannot take the place of a written EMCP they will help reduce risk of non compliance. To get started I suggest the following:
- Review and confirm correct Harmonized and Schedule B codes
- Check EAR regulations for correct exemption codes and license or NLR designations
- If exporting under ITAR you need a responsible trained officer
- Check common “Red Flags” such as denied parties lists, entities lists, and unverified lists
- Review export documentation for possible improvements
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