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export controls

Export Control Compliance Program

Develop and implement an export control compliance program

Appoint a designated export control compliance officer or team

Establish written export control policies and procedures

Conduct regular export control training for employees

Maintain records of export control transactions and activities

Monitor changes to export control regulations and laws

Identify export control risks and develop risk mitigation strategies

Create a system to ensure proper authorization is granted for export activities

Establish internal audits to ensure compliance with export control laws

Implement a process for self-disclosure of non-compliance

Establish an escalation process in the event of a potential export control violation

Develop a mechanism for third party review of exports activities

Classification and Licensing

Classify all products, technologies, and software for export control purposes

Determine if an export license is required for each product or technology

Apply for export licenses when necessary

Maintain records of export licenses obtained

Monitor changes in export control regulations and corresponding reclassification requirements

Review license requirements with customers and vendors

Test and verify export control compliance for third-party vendors

Utilize automated IT tools to track and document export compliance activities

Establish systems to alert personnel of upcoming license expiration dates

Establish audit protocols to ensure continued compliance

Develop and maintain appropriate internal controls to ensure compliance with export control requirements

Create and maintain a secure system for the storage and transfer of export-controlled information

Create and maintain written standards, procedures, and guidelines for export control compliance

Develop and maintain a system for identifying and tracking changes in ITAR and EAR regulations

Restricted Parties Screening

Implement a process for ongoing restricted parties screening

Establish procedures to handle potential matches or hits on restricted parties lists

Technology Control Plans

Identify and document controlled technology or technical data within the organization

Develop and implement technology control plans for controlled technology

Restrict access to controlled technology to authorized personnel

Implement measures to prevent unauthorized transfer of controlled technology

Recordkeeping and Reporting

Maintain records of all export transactions, including shipping documents, invoices, and licenses

Retain records for the required period specified by export control regulations

Report any export violations or suspicious activities to relevant authorities

Conduct internal audits to ensure compliance with recordkeeping requirements

Establish and maintain a system for tracking export transactions and activities

Develop and implement a system for maintaining records of export compliance activities

Create a process for reporting export compliance issues to the appropriate authorities

Develop and implement a system for maintaining records of export licenses and agreements

Create and maintain a database of export-related information for easy retrieval and reporting

Develop and implement a procedure for reviewing and verifying the accuracy of export records

Establish and maintain a system for tracking and monitoring export compliance activities

Develop and implement a procedure for investigating and resolving export compliance issues

Supply Chain Management

Implement procedures to ensure compliance with export controls throughout the supply chain

Evaluate and assess the export control compliance of suppliers and subcontractors

Establish contractual requirements for suppliers and subcontractors regarding export control compliance

Export Control Training and Awareness

Provide regular training and awareness programs on export control regulations for employees

Ensure employees understand their responsibilities and obligations regarding export controls

Establish a process for reporting potential export control issues or concerns

Continuous Improvement and Compliance Monitoring

Conduct regular internal assessments and audits to monitor compliance with export controls

Implement corrective actions and improvements based on audit findings

Stay updated on changes to export control regulations and adjust compliance program accordingly

Regularly review and update export control policies and procedures

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