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The Thirteen Commandments of Export and Import Compliance Programs (6)

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Core Tip:The Thirteen Commandments of Export and Import Compliance Programs (6)

The Thirteen Commandments: No. 6

"Screen For Compliance And Quality"


The US Government uses export and import laws to punish enemies, to protect domestic industries, and to safeguard the national security. As a consequence, there are many people, companies, and even countries with whom you are prohibited from dealing with, and many items that you cannot trade. The US Government tends to punish violators harshly.

Screening is a good idea even if the US Government did not punish violators. Screening is part of your due diligence or standard of care. Screening merely means that rotten apples don't contaminate your company.


You should be screening prospective employees to make sure that they won't commit or hide violations. You should screen contractors and agents to make sure they are reputable. You should screen your products to make sure that they are not adding to the monstrous proliferation of weapons.


If exporting, the Export Administration Regulations provide some helpful "red flags" to alert you that your product is being used in an illegal way or by someone or in some country that is prohibited.


You may hire freight forwarders, consultants, brokers, and others to assist you with your company's exporting and importing. However, your company remains ultimately responsible and liable for any mistakes. Thus, you must choose your agents well, and make sure that they too honor the letter and the spirit of your ICP.

 

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