Export Compliance Program Management ISO 37301

Export Compliance Program Management

Export Compliance Program Management

Effective export compliance program management poses challenges for organizations of all sizes and sectors.  U.S. export regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) are complex and under constant revision.  Compliance is further complicated for organizations that have multinational operations and must therefore comply with additional export controls.

CVG Strategy Export Compliance Management Systems

CVG Strategy export compliance specialists, drawing from decades of experience in the field, have created Export Compliance Management Systems.  These management systems include manuals, work instructions, forms, and attachments that address U.S. export legal and regulatory requirements.  Additionally, management systems are available to address requirements for the Canadian Controlled Goods Program.

These document sets address the all departmental functions in an export compliance system including those for planning, human resources, sales and marketing, engineering, vendor management, and production and services.  They also include the required processes for maintaining export compliance including item classification, screening, anti-boycott compliance, and incident response including instructions for conducting voluntary self disclosure.

Additionally, these documents contain imbedded tools for assessing and rating risks.  These tools can help members of a compliance team identify compliance risks in projects where extra diligence is required to maintain compliance obligations.

These management system document sets are fully compliant with ISO 37301:2021 Compliance Management Systems to provide a coherent method of integration into an organizations existing operations.

ISO 37301 Compliance Management Systems

ISO 37301:2021 is an international standard that can help establish and maintain a culture of compliance within an organization.  It can also extend these expectations to interested third parties.  Application of this standard can provide a basis for a sustainable organization by helping it meet its regulatory obligations.

Since ISO 37301 is structured along the same lines as ISO 9001:2015 it can be harmonized with an organization’s existing  Quality Management Systems (QMS).  While compliance functions are maintained independent from other functions, ISO 37301 compliance management can be integrated with other management processes.

Creating and implementing a successful compliance management system requires that the system fit the organization’s culture and specific regulatory requirements.  This is accomplished by defining a context of the organization that will allow for the creations of policies that are embedded in and reflected by the behaviors of all personnel and interested parties.  These policies should reflect core values and ethical practices incumbent on maintaining compliance to export laws and regulations.

As with any successful business undertaking, an effective export compliance program must start at the top.  Top management must be committed to strict adherence with export laws and regulations.  Management must also allot adequate resources to maintain and develop the compliance program as the business evolves. 

When implementing a compliance program, specific risks must be identified when determining the scope of a program.  These risks, once identified, can be addressed and monitored by the management system.  As with other ISO standards, ISO 37301 employs a Plan, Do, Check, Act methodology that provides an organization a means to engage in continual improvement of processes while accessing new risks and opportunities.

Flexibility in Implementation

There are numerous types of organizations that must comply to export laws and regulations.  Therefore a compliance program must vary to address differences in type, size, nature, and sector of business.  CVG Strategy Export Compliance Management Systems provide flexibility in implementation to be applicable to all types of export scenarios.

As an example, a business may design, service, manufacture, and export dual use products that are not enumerated by the United States Munitions List (USML).  Such an organization would need only comply with Export Administration Regulations (EAR) and not those of the International Traffic in Arms Regulations (ITAR).

Our Export Compliance Management System provides means to determine, tailor, and document which sets of laws and regulations are applicable to an organizations context, thereby preventing unnecessary burdens and overhead.

CVG Strategy Export Compliance Services

CVG Strategy, LLC is recognized the world over as the premier provider of customized Export Compliance Consulting, Export Compliance Programs, and Training that address critical U.S. Government and Canadian laws and regulations, from Export Administration Regulations (EAR), to the International Traffic in Arms Regulations (ITAR), Office of Foreign Asset Controls (OFAC), Canadian Goods Program (CGP) and other regulatory agencies.

CVG Strategy ITAR and Export Compliance experts have managed manufacturing and distribution businesses and have worked for multi-national organizations.  CVG Strategy’s experts are not ex-government employees, they understand the needs and goals of small to medium-sized operations in managing compliance requirements.  They also have expertise in the implementation and maintenance of a wide variety of management system standards.

 

Kevin Gholston

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