Export Compliance Program Eighth Element: Build and Maintain Export Compliance Manual
July 29, 2021
(The Exporting Source)
by Blake Gill *
We have made our way to the final element of
our Export Compliance Program (ECP). This
element can be placed last in the steps for its
maintenance function, or in the event of a
newly established export compliance manual, it
can be the first element. You will need to
ensure there is management support to start
building the manual and that management agrees
to set a positive example within the
organization by acting in compliance with
existing policies and procedures.
Your Export Compliance Manual will be a
direct reflection of your organization’s
activities. The manual may be 10 pages, or it
could be over 100. There is no
one-size-fits-all solution so make sure to
focus on your own company’s needs. You will
want to begin with an explanation of why this
is critical to your company, then follow up
with a commitment statement from top-level
management, such as the CEO. Then, move into
explaining the process and responsibilities of
roles within the organization. Remember to
avoid individual names and to associate
responsibilities with specific job titles to
prevent frequent updates due to employee
turnover.
Finally, your manual is published! While this is a great accomplishment that deserves a celebratory sigh of relief, the job does not stop there. You will need to ensure a regular review of the manual, usually on an annual basis. As the organization grows and adjusts to its market, so will your manual. A successful compliance department is only as good as the support it has from management. Make sure to approach the business in a positive, yes-first attitude. You will need favors at some point, so work to stay in the good graces of all colleagues because a good support system will make life easier.
* 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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