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Implementing Export Compliance Policies and Procedures

Once your company drafts (or revises) Export Compliance Policies and Procedures, you must ensure you take steps to implement these documents properly and that your company is fully compliant with the procedures outlined in them. Prior to finalizing the Policies and Procedures, companies should ensure there is no conflict between their practices and their written procedures and amend either, as necessary, if conflicts are found. Once the procedures are finalized, a copy should be put on the company’s intranet (or in a similarly accessible place for employees).  Employees should also be notified of the procedures with notices throughout the company’s facility alerting that the procedures are in place and how employees can access them. Additionally, employees should be given periodic training on export controls, which should include employees’ responsibilities under the Policies and Procedures. The Policies and Procedures should be reviewed periodically for any changes required based on company procedure changes or export regulation changes and employees should be notified that changes have been made.

 

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