Exporters, what has prevented you from implementing an Export Compliance Program? Here are the most common self-imposed roadblocks:
Inertia- initial steps are taken to develop an Export Compliance Program but progress stalls as more urgent tasks need attention.
Management believes that company is too small or doesn‘t export enough to need a formal ECP.
Lack of upper management commitment and/or willingness to put in the time.
Management doesn’t want to spend the money or devote resources to create an ECP.
Compliance is managed at lower levels with limited authority to get the project done.
Reliance on Logistics Service Providers for compliance. While LSPs are valuable business partners, the exporter is ultimately responsible for compliance.
An effective Export Compliance Program includes these elements: 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 program.
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