Export Compliance Program Sixth Element: Audits 

Export Compliance Program Sixth Element: Audits

July 29, 2021

(The Exporting Source) by Blake Gill *

As we begin to get closer to the last of our Export Compliance Program (ECP) elements, we turn our focus from how to implement the ECP  to how to ensure the elements are properly aligning with our business. This can be accomplished by performing audits against your ECP.

Audits will allow the ECP to be dynamic to the business needs, adjusting aspects of the ECP to better fit where needed. It is best to assemble an audit team to assist the export compliance manager, selecting individuals to represent different areas of the business. This team should have full autonomy and flexibility to carry out audit functions so that they may fairly identify inconsistencies and risk areas. Two of the most common methods of an ECP audit are at the function level and at the program level.

The function level audits will focus on specific areas of individual operations. Specific transactions will be selected, random or not, for review and comparison against the organization’s policy and procedures. It is critical that any areas of policy and procedure that are not utilized or are irrelevant to the function are appropriately addressed. By having “fluff” involved with a function, your company runs the risk that employees are trained to ignore certain areas. This type of behavior and mindset can flow into important business areas and lead to violations.

At the program level, the audit will focus on corporate- level activities. These activities include approving business partners and customers, how export transactions are completed, and how each business unit functions in relation to written policy and procedures. This program level review should occur on an annual basis at a minimum. Executive management should be heavily involved at this level for full visibility and commitment to the ECP.

Once the audit process has been completed, the findings should be shared with the whole business team and followed up on. Additionally, a report should be provided to executive management wrapping up the audit process and explaining the action taken on all findings. Incorporate the lessons learned and some of the critical aspects of the audit into employee training and awareness programs.

* 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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