Commonwealth Trading Partners, Inc.

Self Assessment

Introduction and Instructions

This is a brief assessment tool intended to give busy executives and experts a "snapshot" of the probable compliance readiness of his/her company. The 18 questions below should take 3-5 minutes to complete. Once done, simply submit the form and we will return to you an email summary of strengths and weaknesses, along with a color-coded chart and prioritized recommendations. Your responses will be treated confidentially and there  is no cost or obligation.

Listed below are several statements describing a comprehensive and compliant export control program. In the box beside each statement, indicate your level of confidence that the statement is accurate with regard to your own company . For example, a score of 5 would indicate high confidence that the statement would be true of your company, 4 would indicate a fair level of confidence but with some reservations, 3 would mean only mediocre performance, 2 would denote significant problems, and a score of 1 would mean little or no confidence. If you are not sure of the question or answer, simply put in a 3 for the median score. Do not leave a blank.

Note: This is intended as a convenient tool. It is highly subjective and not meant to replace an on-site compliance assessment.

Your responses will be treated confidentially and there is no cost or obligation.


Begin Snapshot Assessment

Reminder: a score of 5 would indicate high confidence that the statement would also be true at your firm, 4 would mean fairly confident but with some reservations, 3 would indicate only mediocre performance in this category, 2 would denote significant problems, and a score of 1 would mean little or no confidence in the truth of this statement at your company. Note: If you are not sure of the question or the answer, simply put in a 3 for the median score. Do not leave a blank.

  1. Experts from the company regularly attend export control events such as compliance seminars or workshops, and they follow evolving technical or regulatory changes that might affect the compliance challenges of the company.

  2. All new and proposed corporate relationships are vetted for export control compliance, including subsidiaries, distributors, suppliers, contractors, etc.

  3. The company has appropriate levels of physical and information security at all locations.

  4. The company adheres to comprehensive guidance to prevent the inadvertent/unauthorized transfer of tangible and intangible (information) technology to foreign national employees, investors, contractors, distributors, etc.

  5. The company follows comprehensive written procedures and flowcharts to ensure that no company item or technical data is transferred or exported other than as intended.

  6. The company has comprehensive nonproliferation screening procedures being actively used to screen orders/exports against ALL the WMD screens, that is: Nuclear, Missile Technology and Chemical/Biological threats.

  7. The company has adequate nonproliferation procedures (checklists, training, etc.) being actively used to prevent diversion of company products to end users of concern.

  8. The company has recently had all of its licensable items (products, software, technologies) properly classified and is actively attempting to comply with country export (and re-export) restrictions.

  9. The company follows written procedures to ensure Denied Party screening of customers, employees and affiliates, and these procedures cover the full sales cycle: sales, training and servicing.

  10. Appropriate anti-proliferation checks and safeguards are in place within the order processing system and responsibility has been assigned for all checks/screens.

  11. The company has implemented a well-known policy which stresses to all employees an affirmative, no-risk duty to notify one (or more) specific officials in the event of non-compliance.

  12. The company conducts regular and comprehensive Internal Reviews of export control compliance, following written guidelines called for in the EMCP, then systematically seeks to address the various deficiencies that are discovered.

  13. High quality training on export control issues is consistently provided to new and existing staff, notably on the specific and/or evolving policies and procedures in the respective departments.

  14. The export control-related record keeping requirements and methods are well known, and effectively adhered to, in all departments for the duration required by law.

  15. In our company, the employees with export-related responsibilities are well known, easily accessible, and effectively coordinated.

  16. We have a current, well distributed written statement from management (Management Policy Statement - MPS) that communicates the company's strong commitment to export controls on both dual use and military items.

  17. Our export control system is adaptable to major changes, such as the loss of key personnel, new products introduced, or a merger/acquisition.

  18. My company has an effective export management compliance program (EMCP) that is well coordinated and adequately funded.

The profile is complete. Hit the Submit button and the results will be sent to you shortly.


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