Export Compliance Programs
CTP provides multi-phase assistance to assess, develop, deploy and maintain compliance programs.
Faced with increasingly complex compliance challenges and heightened penalties, proactive executives are seeking to manage their risks with the development of an Export Compliance Program. CTP has assisted hundreds of foreign and domestic companies over the past 25 years to develop and deploy these risk management solutions.
Phased Approach with Practical Focus
Based on our experience, we advocate a phased, cyclical approach that stresses planning, practicality, and persistence. The objective is to not only to solve your compliance problems but to keep them solved, resistant to the corrosive effects of internal and external transitions. These are customized, right-sized, and highly practical solutions, developed in conjunction with your own experts in order to harness their institutional knowledge and achieve corporate “buy-in” to the compliance program.
Export Compliance Policies and Procedures Manual
CTP experts frequently help clients create policies and procedures for export compliance under both the ITAR and EAR. Once documented and compiled in a manual, they serve thereafter as the backbone of the Export Compliance Program (ECP), the go-to resource for all staff members. Its importance cannot be overstated.
We work with client experts to tailor our customizable template to meet their specific situation: business model, product classifications, IT systems and, most importantly, compliance requirements. The manual defines various policies and organizational goals, but the essential benefit comes from the specific procedures. For each requirement, we work with client experts who know the existing company SOPs, to answer the key questions in simple, operational terms:
- What is the task?
- Where is it needed?
- When should it be done?
- What does it look like?
- Who should perform the task?
The manual customization process has two important results: 1) The company gets comprehensive guidance that is tailored to their specific needs, and 2) The experts we work with have a better understanding of the risks and requirements since they help devise the solutions. This helps foster compliance awareness and the invaluable sense of “buy in” that positively affects behavior.
Export Compliance Training
The effectiveness of your in-house Export Compliance Program (ECP) depends largely on the accompanying training programs. The experts at CTP can assist you with this critical task, having developed and deployed export control training throughout the U.S. and around the world. We help your staff understand the policies, utilize the procedures, and maintain the interoperability of the system. In the process, we provide the answers and also the rationale behind the questions, empowering your employees with a deeper understanding of challenges and solutions:
- Why are export controls critical to your company?
- What should happen in each department for the system to be effective overall?
- Who performs the respective tasks? How are their efforts coordinated and updated?
- When should things happen to remain compliant and to boost efficiency?
- How are these tasks to be performed? What are the methods and metrics?
On-site training is typically used to launch a new Export Compliance Program, with “Awareness” training for the general staff and focused sessions for both the Compliance team and leadership group. CTP also maintains a web portal with 21 training modules that enable client staff to efficiently review and understand concepts and terminology. Real-time eLearning development is underway for a sophisticated web portal that will feature interactive content within a Learning Management System, enabling clients to track individual and collective usage and performance.
Export Compliance Audits
Proactive companies employ periodic reviews to identify risk areas and serve as the impetus for developing effective solutions to avoid potential violations. Whether conducted at the outset of an engagement or at recurring intervals to monitor performance, our audits/assessments help your organization build and maintain an effective Export Compliance Program. Our experts will review your export control system and compare their findings against the “best practices” listed in the EAR and ITAR.
To be effective, an export control audit should cover all aspects of your business, notably engineering, human resources, order processing, shipping, sales & marketing, and IT/facility security. Not only do we study the functional components of the current export control system, our experts measure the interoperability of the various company policies to identify gaps and potential risk areas. In the final phase, CTP experts will prepare a detailed review of your existing export control system, complete with recommendations to improve compliance. We will show you the challenges and how best to manage them effectively.
Best Practices in Export Compliance
No matter where you start or what challenges you face, the objective is the same:
An effective and efficient compliance program that addresses your current needs, anticipates your future needs, overcomes external and internal transitions, and promotes a culture of compliance within your organization.
It is not a finite task but an ongoing challenge.
How can we help you?
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