Having a strong Internal Control Program (“ICP”) for export compliance is the initial step to ensure that exports and export decisions are consistent with the regulations.
Compliance program governs the actions of senior management, logistics departments, international sales & marketing teams, R&D units, Engineering, Human Resources and other departments regarding the export of commodities, international transfer of software and technical data as well as hiring and hosting the non-U.S. nationals. Essential elements of the program provide checks and safeguards at key steps to better manage the overall export process.
Undoubtedly, not having any program or having a weak compliance program means vulnerabilities in the process. Companies may face a loss of their business reputation, loss of their export privileges, high monetary penalties, and imprisonment with severe or repeated violations. Apart from the fact that an ICP is recognized by the U.S. Government agencies as an indicator of the company commitment to compliance, a robust and well crafted ICP minimizes the possibility of such violations and strengthens the position of the company should any issue develops.
Linqs has an extensive knowledge and expertise in the development of ICPs. Our practice includes the review of the company divisions and business units, export operations and engagements with the non-US entities. Based on the result of our evaluations we tailor the ICP to the company’s exact needs with a clear and practical content.
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