The need for C-level leadership is a common topic among compliance professionals. Here is another example:

Screening export shipments has become routine for most companies involved in international trade. Export software packages can perform this task or it can be manual; using the Consolidated Screening List https://www.trade.gov/consolidated-screening-list or individual lists. No one wants to do business with the bad guys. However, the routine nature of export screening makes it likely that upper level management is not involved in the process.

SUPPLEMENT NO. 3 TO PART 732 – BIS’s “KNOW YOUR CUSTOMER” GUIDANCE AND RED FLAGS

(3) Do not self-blind. Do not cut off the flow of information that comes to your firm in the normal course of business. For example, do not instruct the sales force to tell potential customers to refrain from discussing the actual end-use, end-user, and ultimate country of destination for the product your firm is seeking to sell. Do not put on blinders that prevent the learning of relevant information. An affirmative policy of steps to avoid “bad” information would not insulate a company from liability, and it would usually be considered an aggravating factor in an enforcement proceeding.

For help with exports or developing an ECP (Export Compliance Program) contact mitch@adhoclogistics.com