Essentials of an Export Control Program and what you company needs to have in place in order to help ensure you are on the right track to export compliance.
We will focus on both the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). The Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) both have guidelines of what should be included in the compliance program.
DDTC suggest a comprehensive compliance program includes the following elements:
- Organizational Structure;
- Corporate Commitment Policy;
- Identification, Receipt, and Tracking of ITAR Controlled Items/Technical Data;
- Re-Exports/Retransfers;
- Restricted/Prohibited Exports and Transfers;
- Recordkeeping; and
- Training.
While BIS suggest the core elements of a compliance program are:
- Management Commitment;
- Continuous Risk Assessment of the Export Program;
- Written Export Management and Compliance Program;
- Training and Awareness;
- Cradle to Grave Export Compliance Security;
- Recordkeeping;
- Compliance Monitoring and Audits
- Reporting Export Violations; and
- Corrective Actions in Response to Export Violations.
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Contact TCS if you are ready to start implementing an export compliance program, 214-810-0204 or info@TCSGroup-us.com.