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Division
of Investment and Export
PO Box 7970
Madison, WI 53707-7970
USA
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Vol.
8 #4, March 2009
Trade Compliance Tool
The U.S. Department of Commerce, Bureau of Industry & Security has
published a new tool to aid in the development of an Export Management
and Compliance Program. The tool may be used to create a new
program or to assess whether existing internal controls address common
vulnerabilities found in export compliance programs. It is a
combination of best compliance practices implemented by U.S. companies,
auditing practices, and Export Administration Regulations requirements.
The tool provides a series of checklists of issues to be
addressed. Users can mark an issue as “yes,”
“no,” or “uncertain” and each issue can be
dated and initialed by the person conducting the review. Issues
covered in the checklists include:
- Obtaining management commitment;
- ECCN classifications;
- Checking multiple lists;
- Order process and documentation consistencies;
- “Holding” questionable orders;
- Records retention;
- Audits;
- Training; and
- Other topics.
An effective Export Management and Compliance Program consists of many
interconnected and intersecting processes. The connections and
intersections must be planned, and then, clear directions must be given
to those who are to follow the rules of the program. You can view
and print your own copy of the checklists by visiting http://www.bis.doc.gov/complianceandenforcement/emcp_audit.pdf.
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