In previous posts I have written about export compliance as good risk management. If your company has implemented a formal Export Management Compliance Program you have reduced risk. However, even if you have not implemented an EMCP, it is still good business practice to take some basic steps which can help reduce the risk of non compliance. To get started I suggest the following:
- Review and confirm correct Harmonized and Schedule B codes
- Check CCL Commodity Control List to see if your product is listed
- Check EAR regulations for correct exception codes and license or NLR designations
- If exporting under ITAR you need a responsible trained officer
- Check common “Red Flags” such as denied parties lists, entities lists, and unverified lists
- Review export documentation for possible improvements
For help with export compliance contact mitch@52.91.45.227