Instituting an Export Control Compliance Program

The Issue

The client expressed concern that its plan to begin exporting goods overseas could lead to violations of U.S. export control laws through inadvertently sharing export-controlled technical information or inadvertently shipping goods to a foreign customer when the client should have known of diversion risks.

The Strategy

We advised the client on establishing a strong export control compliance program to meet U.S. regulatory requirements, protect its business interests, and increase the efficiency of its export operations. This program confirmed the commitment of the client’s management to upholding export controls, created an export control compliance team, trained employees in compliance requirements, put in place a system to track shipments, and established internal company procedures to escalate possible export control violations to management for expeditious resolution.

The Impact

The client has implemented an effective export control compliance program, which to date has prevented any violations of export control regulations and mitigated the potential risk of large fines or criminal penalties. Having the compliance program in place and well integrated into daily operations has encouraged the client to expand significantly its foreign exports.

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