Managing an Export Compliance Program

Managing an Export Compliance Program properly ensures its effectiveness.  Any plan, no matter how well conceived, is only as effective as its execution.  Given the importance of export compliance to the sustainability of a business this is a task that must be addressed appropriately.

Technology Control Plan – ITAR

A Technology Control Plan (TCP) is required for companies that are involved in the production of articles specifically designed or otherwise intended for military end-use.  These goods are categorized on the United States Munitions List (USML) and are controlled by the International Traffic in Arms Regulations (ITAR). 

The TCP defines the controls necessary to protect Export Controlled Information (ECI) and ensure complete compliance to the ITAR.  It should include processes for training employees and informing visitors of those controls.  It should also contain actions and procedures to be taken if a violation of the TCP occurs.

Export Control Plan – BIS

An Export Control Plan (ECP) is required for companies that export dual-use commodities.  Dual-use items are classified under the Commerce Control List and fall under the jurisdiction of the Bureau of Industry and Security (BIS).  Dual-use items are commodities that while having civilian uses, may also be used for military purposes.

An ECP consists of processes required to ensure compliance to applicable regulations. These processes must be planned, and provide clear directions for all participants. 

Managing an Export Compliance Program Successfully

Have a Plan

A properly designed export compliance program should be tailored to the unique requirements of the business.  These requirements should include the size of the business, the percentage of sales that are export controlled, and the expected growth of the organization.  The plan should be kept current with changes in regulations and should include procedures to handle compliance issues.

Assign Roles

Defining roles and assigning capable personnel to carry out procedures is essential.  For ITAR, it is a requirement that an Empowered Official be appointed to oversee the compliance program.

Management Commitment

Management commitment is vital in creating and maintaining an export compliance program.  Senior management must show public support for the policies and procedures and provide sufficient resources to the program.  Particular attention should be given to assure that adequate export compliance training is provided.

Conduct Risk Assessments

Risk assessments should be conducted to identify vulnerabilities so that procedures and processes can be developed to mitigate potential violations.  As a program is audited these assessments should be remade to compensate for an inadequacies. 

CVG Strategy Export Compliance Experts

CVG Strategy can help you develop and maintain an effective export compliance program.  Additionally, we can provide the essential training to keep your team current with changing regulations.  We have a regular schedule of informative and engaging webinars.  We also provide quick online answers for your ITAR questions.

 

Kevin Gholston

Kevin Gholston

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