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EXPORT controls

Classification and Determination

Product Classification*: Determine the appropriate Export Control Classification Number (ECCN) or Harmonized System (HS) code for each product.

End-Use Determination*: Assess the intended use of the product and determine if it falls under any restricted or prohibited end-uses.

Destination Country Screening*: Check if the product is going to a country subject to export controls, embargoes, or sanctions.

Licensing and Authorization

Licensing Requirements*: Determine if an export license is required for the product based on its classification and destination.

License Application*: Prepare and submit the necessary export license applications to the relevant government authorities.

License Tracking*: Create a tracking system to monitor the status and progress of license applications.

Compliance and Documentation

Recordkeeping*: Establish a recordkeeping system to maintain all export-related documentation for a specified period.

Export Documentation*: Ensure all required export documentation, such as commercial invoices, packing lists, and shipping documents, are prepared accurately and maintained.

Export Compliance Training*: Conduct regular training sessions to educate employees on export controls, compliance procedures, and potential risks.

Compliance Audits*: Conduct periodic internal audits to assess compliance with export control regulations and identify any gaps or violations.

Supply Chain Management

Supplier Due Diligence*: Perform due diligence on suppliers to ensure they comply with export control regulations and do not pose risks.

Screening Customers and Partners*: Implement a screening process to verify the legitimacy and compliance of customers and business partners.

Technology and Data Controls*: Implement measures to protect sensitive technology, technical data, and intellectual property from unauthorized access or transfer.

Restricted Parties and Embargoes

Restricted Parties Screening*: Regularly screen customers, end-users, and business partners against government lists of restricted parties.

Embargoed Countries*: Stay updated on the list of embargoed countries and ensure no exports are made to these countries unless authorized.

Internal Controls and Reporting

Internal Compliance Program*: Develop and implement an effective internal compliance program to ensure adherence to export control regulations.

Reporting Obligations*: Understand and fulfill any reporting obligations, such as submitting annual reports or providing information to government agencies when required.

Incident Reporting*: Establish a mechanism for employees to report any potential export control violations or suspicious activities.

Continuous Monitoring and Improvement

Regulatory Updates*: Stay abreast of changes in export control regulations, embargoes, and sanctions regimes.

Periodic Risk Assessments*: Conduct regular risk assessments to identify new risks and update existing risk mitigation strategies.

Continuous Improvement*: Continuously review and improve export control processes, procedures, and training programs based on lessons learned and industry best practices.

Note: This checklist should be customized according to the specific requirements and characteristics of the manufacturing organization and the applicable export control regulations in their jurisdiction.

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