Corporate Compliance Case Study: The responsible officials at the company have decided to review a cross-section of their compliance policies and procedures. Here are just a few of the questions they should pose internally:
Is the corporate commitment to export controls strong and well coordinated?
- Has senior management recently issued a compliance Policy Statement?
- Are compliance personnel and responsibilities clearly identified?
- Are there adequate resources deployed (staff and funding) to maintain compliance?
- Is the company tracking the relevant changes in the export control reform initiative?
Is there adequate awareness of, and protection against, technology transfers?
- Does the company employ or contract with Foreign Nationals?
- Is compliance reviewed in dealing with contractors, distributors, affiliates, etc.?
- Are there adequate provisions for physcial and information security?
Is there a strong order processing system?
- Are all the neccessary risk screens conducted?
- Is the recordkeeping adequate in all departments?
- Is there adequate follow-up on license requirements?
CTP Solution: We can help in two ways. First, we can conduct an Assessment/Audit to gauge the effectiveness of the various policies/procedures that are required by the regulations. If gaps are indentified, we can offer prioritized recommendations for specific remediation or work with company experts to design and implement a comprehensive Export Management System.