The volunteers supporting IIEI Certification firmly believes “Voluntary“ Best Practices alone aren’t getting the job done as evidenced by the growing number of violations and violators. Additionally, as fines continue to increase, the quantity, specificity, complexity, severity and cost of government mandated remedial compliance measures are on the rise as well.
IIEI Certification is a strong advocate for implementation and integration of Best Practices into any world class trade compliance program. Without proven Best Practices that fit your organization any international trade compliance effort falls short of doing all that needs to be done to meet globally expanding and demanding multiple-entity regulatory requirements. The question you must ask is: “Is your global trade compliance program super or superficial?” Without Best Practices it’s virtually guaranteed to be the latter.
However, knowing about Best Practices and actually folding them into your international trade compliance program are two different things. Unless Best Practices are part of what you’re doing on a day-to-day basis and have been refined to fit the unique nature of your global integrated trade compliance effort they have little or no value.
Here are some of the industry and US Government sources for best practices and related guidelines for developing world class trade compliance programs. Key elements you must also consider are in the US Sentencing Commission Sentencing Guidelines that make the direct connection between corporate senior leadership and the Board of Directors when it comes to knowledge and oversight of any organization’s trade compliance efforts. As it should, compliance responsibility now stops at the highest level in any organization.
NOTE: Global integrated trade compliance brings together the financial and physical supply chains including exports, imports, customs and all the related elements.
References and Links
Nunn-Wolfowitz Task Force Establishes “Best Practice” Regarding Export Compliance (PDF) A task force commissioned by Hughes Electronics and headed by former Senator Sam Nunn and Ambassador Paul Wolfowitz. (7/25/00).
Guide to Export Controls (PDF) Issued by the U.S. Department of Commerce/International Trade Administration: (7/00)
Best Practices of Compliant Companies from the Department of Homeland Security’s Bureau of Customs and Border Protection (PDF)
Export Management System Guidelines from the Commerce Department’s Bureau of Industry and Security (BIS)
United States Sentencing Commission’s Amendments to the Sentencing Guidelines, Policy Statements, and Official Commentary, which the courts use to determine appropriate criminal penalties. Pursuant to section 994(p) of title 28, United States Code, the United States Sentencing Commission submitted to the Congress these amendments to the sentencing guidelines and the reasons for the amendments. (PDF)
Global Trade Services Best Practices Self Review: A checklist-oriented summary of 14 proven core international trade related benchmarks that highlight core activities, provide supporting rationale and questions keyed to each area.