Commitment: Senior management must establish written export
compliance standards for the organization. They must also
commit enough resources for the export/import compliance program
and ensure that the appropriate senior organizational official(s)
are designated with the overall responsibility for the trade
compliance program to ensure adherence to import/export control
laws and regulations.
Monitoring: Continuous risk
assessment of the import/export program.
A Formal Written
Development of a formal written export management and compliance
program and effective implementation and adherence to written
policies and operational procedures.
Ongoing compliance training and
Compliance Security: Screening of employees, contractors,
customers, products, and transactions. Also implementation of
compliance safeguards throughout the export lifecycle including
product development, jurisdiction, classification, sales,
license decisions, supply chain, servicing channels and
Keeping: Adherence to record keeping regulatory
Trail: Internal and External compliance monitoring and
Procedures: Internal program for handling compliance
problems, including reporting export violations.
Corrective Actions: Completing appropriate corrective
actions in response to export violations.