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Year End Review of Export Compliance Requirements

Another year is coming to a close in a few months making this a good time to review your export compliance program and determine any deficiencies to be addressed prior to year end.

 

Training: All employees who are involved in export- decision making should receive training on a yearly basis.  Additionally, any new export involved employees should be trained within 90 days of hire and should be supervised during their involvement in export activities prior to completion of this training.

 

Audit: A review or audit of your company’s export sales and transactions should also be carried out on an annual basis to ensure compliance to U.S. Export Laws and Regulations and to your company’s Export Policies & Procedures. This review or audit can be completed by the company official in charge of export transactions (the Export Control Officer) or by an external consultant. An audit guide should be drafted and followed to ensure all aspects of export compliance are reviewed.

 

Registration: Yearly compliance requirements include State Department registration renewal, if your company’s manufactured items fall under ITAR jurisdiction. DDTC will email an expiration notice, but you should track the expiration date in case the email is overlooked.

 

Licensing: Exporters should also review expiring licenses and apply for renewal/replacement licenses several months prior to expiration to prevent a gap in licensing. Review of licenses and agreements should include review of any licensing authority required to be replaced or amended due to Export Control Reform.

 

Policies & Procedures: Companies should review their Export Policies and Procedures yearly and make any necessary updates based on changes in regulations or internal company procedures.  This is also a good way to refresh export involved employees (along with an audit/review) on the requirements included in the Policies and Procedures and confirm that the written procedures are being followed and are understood.

 

Vendor/Supplier Certifications: Prior to your company’s transfer of controlled technical data, vendors and suppliers should be required to confirm their compliance with ITAR/EAR regulations through a supplier certification letter, which should be received and updated on an annual basis.  A system should be implemented to track the dates the certifications are signed to ensure new certifications are received annually.

 

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