An Export Control System is an aggregation of policies and procedures and a Compliance Manual is a detailed description of all these aspects. This written guidance, complemented by flowcharts, diagrams, checklists, etc., serves multiple purposes: (1) ensuring task and role specificity; (2) an absolute reference for training purposes; (3) a baseline for developing performance and quality metrics; and (4) a source document for developing complementary compliance guidance.
The Compliance Manual is essentially the playbook for the overall Compliance System. The policies tell people what they are supposed to do and the procedures tell them how to do it. Both are important, and both should be included in your export compliance manual.
We are often asked: “Do I have to develop it myself? Can’t I just buy a Compliance System?”
The answer to both questions is “Yes.” You can buy a basic system, but the real value – the quality and efficiency – comes from the customization. You need to tailor the policies to meet your company goals and priorities, then fine tune the procedures in each department so that they intertwine effectively and seamlessly with your other SOPs. This fine-tuning should be done with the participation of the responsible person(s) in each department, ensuring that the procedures are correct and viable and increasing the sense of “buy-in” among the staff. Procedures will work best if they are instilled rather than installed.
To help you achieve both objectives, CTP will provide the framework of the manual, complete with all the tools, templates, guidance and samples to get started, plus weekly initial support for your compliance staff as they customize the procedures to meet your needs in each department. In the process, CTP will ensure that your experts understand the risks and requirements in each compliance situation, as well as the procedure designed to effectively comply. We can supplement this progression with web-based training modules, designed for the task. We can also help you customize an internal audit/assessment tool that will enable you to measure efficiency.
Together, these tools provide the necessary solutions to keep your company compliant. They are preventative in nature, enabling you to proactively manage risks and avoid violations.