Export Control Training
Export control training is an essential part of an effective export compliance program. Both the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) recommend regular training for all employees involved in exports. For businesses that are involved with International Traffic in Arms Regulations (ITAR) this includes employees that have access to controlled information.
Elements of Effective Export Compliance Programs
The BIS and the DDTC recognize eight elements crucial to an effective export compliance program:
- Management commitment and organizational structure
- Risk Assessment that identifies risks and builds controls
- Processes that ensure that the organization makes correct decisions, tracks and protects exported items, and screens all parties associated with a transaction
- Record keeping in accordance with requirements
- Training for all involved employees
- Periodic audits to access the integrity of the program
- Procedures for reporting and addressing violations
- An export compliance manual that defines processes, roles, and responsibilities
Changing Regulatory Landscape
In recent months there have been major changes in export regulations. Ignorance is not an adequate defense for violation of these regulations. Therefore it is important to maintain an up to date export compliance knowledge base. When investigating export compliance incidents, export enforcement agents are instructed to assess an organization’s compliance program . As a result, when programs are found negligent, increases in civil fines, penalties, and criminal prosecution occur . Specific items of concern are:
- Is the corporation’s compliance program well designed?
- Is the program being applied earnestly and in good faith? In other words, is the program adequately resourced and empowered to function effectively?
- Does the corporation’s compliance program work in practice?
CVG Strategy Export Control Training
CVG Strategy provides a one-day live export compliance webinar. This training covers the regulatory and statutory framework of export law. It covers the key principals and essentials of ITAR and EAR Export compliance. Subjects covered in this training include:
- ITAR and USML (U.S. Munitions List).
- EAR and CCL (Commerce Control List).
- Registration with the State Department.
- ITAR and EAR technical data controls.
- ITAR and EAR licenses.
- Compliance and enforcement.
- Transition of hardware and technical data from the USML to the Export Administration Regulations (EAR)
- Regulation of brokering activities.
- Using classification of articles to organize the necessary controls for US Law.
Other CVG Strategy Export Services
CVG Strategy, LLC is a premier provider of customized ITAR Consulting and ITAR & Export Compliance Programs. Visit our ITAR store for badges, signs, and visitor log books to help with your facility security requirements. We also offer answers to your ITAR questions. Contact Us today to see how we can help your export compliance program.