1.    Have strong and continuous Management Commitment. In order to build and maintain an effective program senior management must:
       •    Publicly support compliance policies and procedures
       •    Provide sufficient resources
       •    Support export compliance training and training sessions

2.    Identify and mitigate your organization’s potential vulnerabilities by conducting frequent Risk Assessments.

3.    Write and implement Export Authorization procedures on jurisdiction, classification, licensing and screening.  This is vital for preventing your organization from exporting unauthorized items and possibly facing export penalties.

4.     Assign individuals roles in Recordkeeping and ensure procedures meet the requirements in EAR § 762.4.

5.     Require Training for all employees, including support staff, whose responsibilities relate to exports in order to keep up with changing regulations and to network with other export compliance practitioners.
 
6.     Perform regular Audits to gauge how well procedures are implemented and how elements need to be augmented.

7.    Implement a program to Handle Compliance Issues, including how to prevent export violations and how to complete corrective actions when a violation is found.

8.    Whether writing an ECP for the first time or maintaining an ECP, make sure to keep the manual current and relevant to the members of your organization.

 

See BIS' seminar schedule for ECP training offered to assist in developing or enhancing your organization's ECP.

   
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