Following up on my last post, here are the elements of an effective Export Compliance Program:
Management Commitment, Risk Assessment, Export Authorization (Agency Jurisdiction), Record Keeping, Training, Audits, Handling Export Violations (Corrective Action), and Build and Maintain an ECP Manual.
The most important element, by far, is Management Commitment. C-Level executives must allocate resources, communicate the importance of an ECP throughout the organization, and hold everyone accountable. Without strong management commitment and involvement you will end up with a weak ECP.
I’m always amazed when clients tell me that they leave export compliance in the hands of their shipping department. Let shippers do what they do best by moving the product. Don’t expect them to be regulatory experts.
If you are relying on your busy shipping department or your logistics service provider for export compliance you are at risk. While risk management always gets C level attention, export compliance is often a mid-management or lower level function. Fines and penalties for violations should make export compliance a basic part of risk management.
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