When was the last time you conducted a thorough audit of your internal control program? Do you need an audit or a compliance assessment?

The Audit

An export compliance audit is designed to quantify a company’s level of compliance with applicable trade control regulations. The audit is an exhaustive, comprehensive review of export transactions, typically going back five years, to determine if proper classification, license determination, applicability of license exceptions, and export documentation is compliant with the regulations. If discrepancies are found, a review of the affected processes and procedures may be performed. The results of the audit will establish a quantified error ratio, and the facts which may be relevant to any potential violations. Audits are typically performed either in anticipation of an acquisition as part of the ‘successor liability’ due diligence, or as a result of the discovery of a possible or actual export violation.

The Assessment

An export compliance assessment is an attempt to qualify a company’s level of adherence to existing trade control processes and procedures. The assessment has two main activities; the gathering and analysis of “soft data”, and the gathering and review of “hard data.” “Soft data” consists of interviews of compliance process stakeholders, while “hard data” are the processes and procedures, and other relevant documents; e.g., export licenses, commodity jurisdictions or classification request results, etc.

With the proprietary Trade Compliance Group assessment methodology, the assessment provides management with a weighted and graphical assessment of a company’s trade compliance processes and procedures. Additionally, our methodology uses this information to place the company on a risk/exposure grid for a more meaningful representation of the compliance program relative to the company’s business model. The assessment deliverable also includes standard ‘gap’ analysis and specific recommendations for corrective actions. The assessment is designed to accomplish the following objectives:

  • Determine if all required export compliance processes are properly documented, and whether policies and procedures have been kept current, and are being followed by employees
  • Verify compliance with license determination and screening requirements and restrictions on destination, end-use, and end-users.
  • Confirm that required export licenses and authorizations are being obtained and properly decremented, and that the company is in compliance with all license conditions
  • Determine whether all export records are being maintained, and in accordance with outlined procedures.

 

Contact us to learn more about compliance assessment and audit services.