With increased scrutiny of export compliance, exporters should have an effective compliance system in place. At the recent BIS Export Control Forum in Newport Beach CA, Assistant Secretary for Export Enforcement Darryl Jackson gave a presentation outlining nine principles of export compliance used to evaluate the effectiveness of an export compliance program and determine whether mitigation of an administrative penalty is warranted. These nine principles include:
· Meaningful Risk Analysis
· Written Compliance Programs
· Responsibility for Oversight by a Senior Official
· Adequate Employee Training
· Adequate Customs and Transaction Screening
· Compliance with Recordkeeping Requirements
· Internal System for Reporting Violations
· Internal and External Reviews/Audits
· Remedial Actions to Address Violations
Similar to import compliance programs, exporters must be able to demonstrate that the nine principles are applied in business transactions and not just something put on paper to satisfy the government. The export compliance programs must also be reviewed and updated to reflect changes in business practices and government regulations. Click on the following links to view Jackson’s speech and presentation.
· Meaningful Risk Analysis
· Written Compliance Programs
· Responsibility for Oversight by a Senior Official
· Adequate Employee Training
· Adequate Customs and Transaction Screening
· Compliance with Recordkeeping Requirements
· Internal System for Reporting Violations
· Internal and External Reviews/Audits
· Remedial Actions to Address Violations
Similar to import compliance programs, exporters must be able to demonstrate that the nine principles are applied in business transactions and not just something put on paper to satisfy the government. The export compliance programs must also be reviewed and updated to reflect changes in business practices and government regulations. Click on the following links to view Jackson’s speech and presentation.
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