The current logistics environment is as challenging as I have ever seen. Tight capacity in trucking, containers not available where needed, astronomical ocean rates, and shortages of critical components. These are just a few of the problems confronting supply chain managers on a daily basis. So it is understandable that compliance may be taking a back seat at the moment. Who has the time or energy to deal with that annoying compliance person? As a proud compliance geek, let me offer the following.
Compliance is about attention to detail, consistency, process, and oversight. I guarantee that your compliance folks are not trying to practice “sales prevention”. The goal is to complete transactions the right way, avoid customs or logistics delays and reduce exposure to fines and penalties. However, there is no doubt that complying with all of the agencies involved in international trade generates a lot of red tape and can be frustrating.
Compliance managers must have the authority to stop shipments when red flags appear. In order to ensure independence compliance folks should not be in the supply chain, finance, or marketing chain of command. Better reporting relationships would be with the legal department, CEO, or COO.
Consider just a few of the details that can make or break a smooth transaction:
Harmonized Codes to the full 10 digits including heading and sub heading. It is very easy to transpose digits.
Schedule B Codes, ditto
ECCN , Alpha numeric, number, letter, followed by 3 numbers. Example 4A994. Then followed by sub paragraph level and don’t forget the dot between the last number and the sub para.
License Exceptions are designated by 3 letter codes and must be compatible with the ECCN listed.
COO, Country of Origin markings and proper codes on documents and AES filings. Best not to guess here. Have you ever entered CH for China?
Valuation must be determined accurately and is best covered in a separate post which I have done on 05/09/2019.
These are just some of the basics. We could also mention commodity descriptions, red flag screening, incoterms, and plenty of other details. So, hats off to the compliance teams.
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