Every company involved in international trade needs an export compliance program tailored to its specific needs. Those dealing in sensitive items such as dual use goods or in countries subject to sanctions will need a sophisticated set of controls and processes to avoid violations and to satisfy the requirements of regulators. Even those engaged in lower risk trade cannot afford to disregard basic compliance requirements such as sanctions screening and contractual protections. Solid Plan will help you understand the risks specific to your business and to build an effective compliance program tailored to match your needs and your resources.
Elements of an effective compliance program
No one involved in international trade can afford to disregard the risks associated with export controls and international sanctions. Regulators in the US, EU and elsewhere expect companies to understand their risks and to implement compliance programs commensurate with them. For smaller exporters involved in trade of non-sensitive items, relatively simple measures such as the use of sanctions screening tools and contractual clauses may be enough. However, all larger exporters, their banks and particularly those involved in business with sensitive items or sensitive regions have to develop more sophisticated compliance programs. The program has to be tailored to address the risks specific to the company, but each one will generally include the following key elements:
(1) Management Commitment
(2) Risk Assessment
(3) Written Policies and Procedures
(4) Screening Processes
(7) Monitoring and Auditing
(8) Reporting Channels for Employees
The key is to implement all these elements in a program that appropriately addresses the risks specific to our company, keeping it safe from financial and reputational damage - while allowing your business the agility and flexibility it needs to beat its competition.