Paper ECPs

Last week’s post described common roadblocks to establishing Export Compliance Programs. In some cases exporters may be under pressure to put a program in place quickly with the focus on creating the ECP manual. This approach ignores the foundation needed for an effective program. The likely result will be a glossy manual that will sit on the shelf and have little impact on operations.

Compliance professionals know that an effective ECP must include C- level commitment and involvement, sufficient funding, well defined and documented responsibilities, on-going training, and internal audits. Weak ECPs lack some of these elements and are simply window dressing or paper programs.

In house compliance professionals are often given responsibility without authority. Further, they may be at mid or lower management levels or in the wrong chain of command. With or without a formal ECP, compliance professionals must have the authority to place holds on questionable exports without being overruled by sales, finance, or supply chain. Well written protocols for resolving issues and releasing holds require C-level or legal approval.

All of the above illustrates the importance of compliance independence. This may mean reporting to the CEO, COO, or legal department in order to remove pressure from other groups.

If your in house compliance professional is not truly independent hire a consultant!

Contact mitch@ for immediate assistance.