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About the Author

Suzanne Richer
Director, Trade Advisory Practice
Amber Road

Suzanne M. Richer joined Amber Road in 2015 to lead the development of a Trade Advisory Practice. She is a licensed customs broker and Certified Classification Specialist™ (CCLS™). Ms. Richer has extensive experience in advising corporations on Focused Assessments, C-TPAT cargo security applications and validations, and the Importer Self-Assessment (ISA) program. She has conducted over 3,000 hours of training, and has authored 12 books on international trade.


Prior to joining Amber Road, Ms. Richer established Customs & Trade Solutions, Inc. During her eighteen years as a trade advisor, she led C-TPAT validations all over the world, and guided many firms into the coveted Tier 3 status of the program. Her work in ISA has earned many of her clients the title of Trusted Partner with Customs and Border Protection.


For more information, please visit www.amberroad.com.


Supply Chain Comment

By Suzanne Richer, Director, Trade Advisory Practice, Amber Road

May 28, 2015



Developing an Effective Export Compliance Audit Process

Key Attributes that are the Foundation of Export Compliance and the Audit Process



The foundation of an effective export compliance program begins early in the supply chain, long before the product is boxed and ready for pick up.   Too often companies consider export compliance and screening requirements at the eleventh hour – when goods are going out the door. Operational excellence begins when the product is in development and leading exporters have developed export compliance strategies early in the process to successfully avoid potential problems, which can include fines, jail time, loss of export privileges, and diminished brand equity.

Exporters with best in class operations exhibit several key attributes that rise above the average firm, ensuring their product arrives on time, with limited risk.   The foundation of their export compliance and audit process includes many of the following:

Richer Says:

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Operational excellence begins when the product is in development and leading exporters have developed export compliance strategies early in the process to successfully avoid potential problems, which can include fines, jail time, loss of export privileges, and diminished brand equity.
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 1.

Export risk models. Risk in the supply chain is unique to each corporation and is dependent on the size of the company, what it exports, where it exports and how much it exports. Shipment complexity includes the product’s end user and other factors all play a part.

Export risk models should be reviewed and evaluated annually to ensure company executives and all key personnel understand it, are familiar with it, and are actively taking steps to reduce that risk. Unfortunately, risk cannot be passed off to a third party, such as the freight forwarder. Companies operating under that myth often discover the hard way, through fines and penalties, that their trust was misplaced. A great way to analyze potential risks is to develop a matrix/decision model risk model focused at both the company and product level.

 2.

Written procedures tied to an exporter’s risk. Companies should have tailored, written procedures documenting how to manage transactions against specific risks, including policies and procedures with clear accountability. These procedures should not only cover potential risks, but the company’s level of vulnerability to those risks. Each person involved in the export transaction should be familiar with, and capable of, fulfilling these responsibilities. Companies should require senior management to review these procedures annually and confirm their applicability to current processes.

 3.

Mandatory annual export training. Effective export compliance programs identify who needs to be trained, based off the written procedures, and ensures their training is ongoing . This is especially important for new employees taking over existing export roles. Key personnel should be trained to the degree necessary, including programs on regulations and ethics. Creating a corporate culture that promotes an atmosphere where it’s OK for employees to ask questions is ideal and training should be linked to an individual’s job evaluation. A best practice would include training for contractors as well.

4.
A cross-department compliance team. Great export teams include individuals from sales, accounting, manufacturing, customer service and legal departments. All departments involved in the export transaction should be identified and included on the team to ensure their involvement in the development of written procedures and to garner their support for meeting company objectives.

Increase full participation by having team members rotate leading the call. Having a compliance team that regularly communicates information to employees demonstrates that a company is engaging in due diligence and has exhibited reasonable care, which can mitigate penalties if they occur.

5.
Monitored performance. Pre shipment audit checklists ensure that all employee involved in the process are taking a consistent approach to the handing of the export. Post shipment audits provide the company with an opportunity to see the full picture, identify anomalies and share that information internally so that errors are not repeated.

External audits should be organized on annual basis, with a full export gap analysis report provided to senior management to review. This report also provides a window to changing company risk and can be tied into the update of the risk model. Best practices for auditing include reviewing a certain percentage of files monthly, and ensuring the auditor was not the same person who created the shipment.

6.
Consider automation. Restricted party screening, for example, can be difficult without automation. These lists – and there are hundreds globally - change constantly. When exporting from the United States, not only do you need to comply with all U.S. restricted party lists, you also may be required to comply with some international lists, depending on where you are shipping.

Final Thoughts

In short – don’t wait until it’s too late. A successful export compliance program involves planning, active participation, training and monitoring. Addressing problems before they start reduces headaches down the road.

 

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