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Managing Export Compliance (Part 3 of a 3 Part Series)

by Thomas A. Cook

In 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.

Importance of Internal Education and Training

Internal 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.

A good 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 company’s bottom line
- 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 standard
- senior management will provide guidance on the execution of the agreed strategies to be used throughout the company

Middle 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 employee’s indoctrination schedule along with their becoming familiar with the latest benefit plan, for example.

Degree of Training

The 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 the program.

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.

Training 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.

Sources of Education and Training

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.

There 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 training programs.

One 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.

Resource Development

As the compliance officer further defines his role and networks himself with outside organizations he must funnel that information to the troops.

The 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 today’s
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 month?

A company 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.

Magazines 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.

The 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.

Procedures 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’.