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Audits

Export compliance audits and reviews should be done on a periodic basis and are a fundamental aspect of a complete export compliance program. Audits should survey both a company’s adherence to their own internal policies and procedures, as well as governmental regulations (i.e. ITAR, EAR). Audits should include discussions and reviews of documentation from various functional departments, including shipping, accounting, and purchasing. Export invoices and other export documents should be reviewed to ensure compliance with product licensing, marking of technical data, controls on foreign national employees, etc.

 

Audits may bring to light non-compliance with U.S. export laws and regulations that should be disclosed to the appropriate U.S. government agency. A voluntary disclosure is generally seen by the U.S. government as a mitigating factor to help reduce penalties for noncompliance if an investigation is pursued by a U.S. government agency. Corrective action to any violations discovered through an audit or review should be taken within 30 days to ensure compliance with U.S. export laws and regulations.

 

The end of the year is a good time to perform an audit or review to ensure your company’s compliance to U.S. export laws and regulations and that the required procedures are properly in place for the following year.

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