Export Compliance Program Fifth Element: Training

July 21, 2021

(The Exporting Source) by Blake Gill *

Our last discussion was on the recordkeeping element. One of the most critical points of recordkeeping is the proper training of who, what, when and where. In order to properly record and store documents, the appropriate individuals need to be trained on their responsibilities and how to accomplish them. Naturally, we understand how an Export Compliance Program (ECP) cannot succeed without an effective training element.

Employees are often consumed with daily duties and find it difficult to dedicate time to export compliance training. With this being understood, it is important that training is made specific to the knowledge needed for the job, communicates the employee’s responsibilities in the export process, and assesses the employee’s knowledge.

The training program should also include periodic reviews. As regulations change and export control reform takes place, the training material will need to be appropriately adjusted. Without an updated training program, employees may face the challenge of making decisions within export control without having the appropriate knowledge, increasing the risk of violation for the organization.

Each company will have training geared toward their specific activities and the regulations that govern those activities. While it is important to focus on job-specific training for export compliance, a well-rounded training program will also include general topics that are applicable to everyone. This includes identifying specific terminology used in the EAR, such as what is considered a U.S. Person, what is the definition of technology, and what is a Deemed Export.

The training aspect of the ECP is one of the most critical because you are relying on many other individuals to maintain a compliant mindset while completing their daily duties. Practice makes perfect, so make sure to revisit training with all employees on a regular basis, mix it up, make it fun, and most of all engage the people with an encouraging manner!

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* Blake Gill is an experienced International Trade Compliance professional with a demonstrated history of work in the technology industry. He has many years of experience working with export control, customer screening and item classification over a wide variety of products. Additionally, Blake has performed the duties of Empowered Official at multiple international companies.