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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