Thomas A. Cook
establishing its export compliance program, the corporation
has nominated its corporate compliance officer and created
a set of standard operating procedures (SOPs).
The key to bringing the program to fruition is to establish
an internal education and training program.
of Internal Education and Training
education and training will enable the corporation to develop
its own in-house expertise. As the compliance officer matures
in his new role he will be developing outside resources
on which to expand his knowledge. At the same time, one
of the many responsibilities of the compliance officer is
to disseminate information regarding the compliance program
and newly established procedures.
export compliance program outlines the framework for the
training. Compliance training should begin with senior management
for several reasons:
- compliance is directly related to the companys bottom
- senior management will understand the importance of compliance
and therefore support the efforts of the compliance manager
through additional funding as well as giving the hammer
to be used by the compliance officer to enforce the new
- senior management will provide guidance on the execution
of the agreed strategies to be used throughout the company
management and support staffing must also be included in
training. There should be a company directive stating newly
hired employees with specific supply chain responsibilities,
will require an export compliance overview within 30 days
of date of start in the new position. This type of directive
requires the cooperation and assistance of the human resources
department. It can be incorporated as part of the new employees
indoctrination schedule along with their becoming familiar
with the latest benefit plan, for example.
levels of training will vary depending on the import/export
responsibilities of the employee. As a minimum, all company
personnel should be included in a basic compliance class.
Everyone in the company, shipping, receiving, accounting,
customer service, sales, should be required to attend. Everyone
in the company would then be made aware of the compliance
program in place within the corporate structure and that
senior management is on the same page backing
Accounting, sales, customer service and operations training
should include Incoterms, letters of credit, types of payments,
risks of global trade and denied parties screening. Operations,
shipping and receiving training should include import/export
documentation, NAFTA procedures, packing, marking, and labeling
and valuation issues.
topics should also encompass regulations under other government
agencies such as Food & Drug Administration, U.S. Department
of Agriculture, Department of State and Department of Transportation,
to name a few. Whatever the topics, they should cover the
specific needs of the organization.
of Education and Training
programs and seminars are offered through different venues.
Some programs are offered in connection with international
trade organizations such as: Society of International Affairs,
Professional Association of Import/Export Compliance Managers,
World Trade Institute, Global Training Institute.
are also government-sponsored programs available such as
Business Executives Enforcement Team (BEET). These BIS/BEET
meetings are held in conjunction with local business associations.
The BIS website contains a comprehensive list of upcoming
of the many benefits of attending these seminars is the
access to the government personnel who are approving license
applications, dispensing advice and enforcing the regulations.
These personnel represent an important resource to the compliance
manager and are available for in-house visits through their
agency outreach programs.
compliance officer further defines his role and networks
himself with outside organizations he must funnel that information
to the troops.
corporate compliance officer must continue to update the
supply chain. U.S. Customs and the Bureau of Industry and
Security (BIS) have daily updates in todays
post 9/11 environment. Employees that have received training
and are familiar with their day-to-day responsibilities
need to be informed of the latest changes. Is UPS going
on strike, will there be port delays in Long Beach next
website with a compliance corner may offer some
corporations a good solution. Other companies may choose
to broadcast updates by email to appropriate
personnel within the supply chain.
and newsletters once read should not be tossed away but
should make their way around the office. Notable website
links should be sent to all in the company address book.
corporate compliance officer is also a resource within his
company. He must advertise his position to make sure the
appropriate person is answering the compliance questions.
in place, corporate support and the nomination of the corporate
compliance officer are the fundamentals of the compliance
team. The corporate compliance officer is part of a team
and part of a team effort. The best strategy will not work
if the team is not working together. It is said a
dedicated team is the fuel for progress and growth.
The same lies true for the corporate compliance officer
and his supply chain team.