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Develop a compliance program for import-export operations. Learn risk assessment, written procedures, and relationship building with U.S. officials. Essential for managerial commitment.
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Long Island Import Export Association September 14, 2017 Compliance Measures Ray Zizzo Baruch Instructor International Trade
A managerial commitment is essential for an effective Compliance Program. (Resource allocation) A manager must be the one responsible for the development and oversight of the Compliance Program.
Conduct an assessment of your operation, identify risk factors associated with the shipments you handle. Example: DOS ITAR Controlled Commodities DOC EAR Dual-Use Commodities Potential violations?
Written procedures or guidelines are paramount. • Chronological order: Step-1, Step-2, Step-3 • Each step must be clear and concise • Organized: Binder - vital resource - training tool • Utilize word doc - regulation changes & updates • (update ex.- armored vehicle - email) • Company size is not a factor • Management must impress upon their employees the importance of following procedures. (no shortcuts) • Encourage employee input.
Final analysis of documentation prior to export is critical. • DSP-5 (ammo multiple calibers-large shipment-high value) • Invoice • AWB • Shipper’s Letter of Instruction • Shipper’s Declaration for Dangerous Goods • MSDS • AES filing printout
Building relationships with U.S. Government Officials. JFK CBP Pipeline Email Distribution List JFKPIPELINES@cbp.dhs.gov