Export Compliance Program Eighth Element: Build and Maintain Export Compliance Manual

July 29, 2021

(The Exporting Source) by Blake Gill *

We have made our way to the final element of our Export Compliance Program (ECP). This element can be placed last in the steps for its maintenance function, or in the event of a newly established export compliance manual, it can be the first element. You will need to ensure there is management support to start building the manual and that management agrees to set a positive example within the organization by acting in compliance with existing policies and procedures.

Your Export Compliance Manual will be a direct reflection of your organization’s activities. The manual may be 10 pages, or it could be over 100. There is no one-size-fits-all solution so make sure to focus on your own company’s needs. You will want to begin with an explanation of why this is critical to your company, then follow up with a commitment statement from top-level management, such as the CEO. Then, move into explaining the process and responsibilities of roles within the organization. Remember to avoid individual names and to associate responsibilities with specific job titles to prevent frequent updates due to employee turnover.

Focus on making the manual as straightforward and clear as possible. Including process flows and visual representations will make the manual easier for all employees to understand. Include your team in the writing process to include their insights and feedback for all elements. Once the draft is complete, have your team proofread and review the entire manual for adjustments. It may also be a good idea to select individuals from within the company, not on the team, that can provide an outside opinion on the draft. When the team has agreed on the draft, it will be ready for publishing. Keep in mind, this process may take several months to fully complete and implement.

Finally, your manual is published! While this is a great accomplishment that deserves a celebratory sigh of relief, the job does not stop there. You will need to ensure a regular review of the manual, usually on an annual basis. As the organization grows and adjusts to its market, so will your manual. A successful compliance department is only as good as the support it has from management. Make sure to approach the business in a positive, yes-first attitude. You will need favors at some point, so work to stay in the good graces of all colleagues because a good support system will make life easier.

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* 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.