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The Thirteen Commandments of Export and Import Compliance Programs (8)

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The Thirteen Commandments: No. 8

"Develop an ICP Manual"


Not only will a written manual simplify compliance, but it also proves to the US Government that your company takes compliance seriously. A compliance manual should be as short and simple as possible. Create visual aids and resources lists. For example, create matrices of documents you keep and where they are kept.

You should be able to reduce any process, policy, or information to a user-friendly flowchart, checklist, or matrix,. If you can't do this, then the process, policy, or information is too complicated for others to follow. Go back to the drawing board.


Your compliance manual should list helpful contacts. Include contact information not only for people within your company, but also for key people in affiliated companies, outside legal counsel, brokers, freight forwarders, consultants, agents, and trade associations.


Also list important government agencies. For example, the Bureau of Export Administration assists with classifying items that are exported, the Census Bureau provides hands-on help on how to prepare export documents, and the International Trade Administration provides "scope reviews" to let you know whether you owe antidumping duties. Also describe the process needed and authorization required before any outside firm or government agency can be consulted.


As part of your ongoing compliance training, you may want to develop a library of helpful resources. This can include books, videos, and software packages.

 

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