Export Compliance Program Sixth Element: Audits
July 29, 2021
(The Exporting Source)
by Blake Gill *
As we begin to get closer to the last of our Export Compliance Program (ECP)
elements, we turn our focus from how to implement the ECP to how to ensure
the elements are properly aligning with our business. This can be accomplished
by performing audits against your ECP.
Audits will allow the ECP to be dynamic to the business needs, adjusting
aspects of the ECP to better fit where needed. It is best to assemble an audit
team to assist the export compliance manager, selecting individuals to represent
different areas of the business. This team should have full autonomy and
flexibility to carry out audit functions so that they may fairly identify
inconsistencies and risk areas. Two of the most common methods of an ECP audit
are at the function level and at the program level.
The function level audits will focus on specific areas of individual
operations. Specific transactions will be selected, random or not, for review
and comparison against the organization’s policy and procedures. It is
critical that any areas of policy and procedure that are not utilized or are
irrelevant to the function are appropriately addressed. By having “fluff”
involved with a function, your company runs the risk that employees are trained
to ignore certain areas. This type of behavior and mindset can flow into
important business areas and lead to violations.
At the program level, the audit will focus on corporate- level
activities. These activities include approving business partners and customers,
how export transactions are completed, and how each business unit functions in
relation to written policy and procedures. This program level review should
occur on an annual basis at a minimum. Executive management should be heavily
involved at this level for full visibility and commitment to the ECP.
Once the audit process has been completed, the findings should be shared
with the whole business team and followed up on. Additionally, a report should
be provided to executive management wrapping up the audit process and explaining
the action taken on all findings. Incorporate the lessons learned and some of
the critical aspects of the audit into employee training and awareness
programs.
* 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.
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