Title Page

  • Company

  • Location
  • Compliance Manager

  • Conducted on

Export Compliance Checklist

Risk Assessment

  • Is there a written procedure that describes how items are classified under ECCNs on the CCL?

  • Does a technical expert within the company classify the items?

  • If your company does not manufacture the item, does the manufacturer of the item classify it?

  • Is there a written procedure that describes when a classification will be submitted to BIS and who will be responsible?

  • Is there a written procedure that describes the process for seeking commodity jurisdiction determinations?

  • Is an individual designated to ensure that product/country license determination guidance is current and updated?

  • Is there a distribution procedure to ensure all appropriate users receive the guidance and instructions for use?

  • Is there a list that indicates the name of the persons responsible for using the guidance?

  • Are embargoed destinations displayed?

  • Are item restrictions displayed? (i.e., technical parameter limitations, end-user limitations)

  • Is there a “hold” function to prevent shipments from being further processed, if needed?

  • Is there a procedure to distribute and verify receipt of license conditions?

  • Is there someone designated to distribute and follow-up with acknowledgment verification?

  • Is there a response deadline defined when conditions are distributed?

Security and Screening

  • Are there written procedures to ensure that checks and safeguards are in place within the internal process flows, and are there assigned personnel responsible for all checks?

  • Select the following checks included in the internal process:

  • Does the procedure explain the order process and other linking processes from receipt of order to actual shipment?

  • Does the procedure include who is responsible for each screen/check throughout the flow?

  • Does the procedure describe when, how often, and what screening is performed?

  • Are hold/cancel functions implemented?

  • Does the procedure clearly indicate who has the authority to make classification decisions?

  • Does the company have an on-going procedure for monitoring compliance of consignees, end-users and other parties involved in export transactions?

Recordkeeping

  • Are there written procedures to comply with recordkeeping requirements?

  • Do the written procedures clearly describe detailed step-by-step processes that employees are expected to follow?

  • Are all records in each process included in the records maintained?

  • Are the written procedures reviewed for update at least annually and when significant changes occur?

  • Are the written and operational procedures consistent?

  • Is there a designated employee responsible for management and maintenance of recordkeeping?

  • Identify all other employees who are held accountable for specific recordkeeping responsibilities.

  • Designated Employee
  • Employee Name & Responsibilities

  • Do the designated employees know who is responsible for the next action to be taken in the process?

  • Do employees understand the importance of their roles related to the overall recordkeeping requirement?

  • Do employees have the appropriate budgetary, staff, and supporting resources to perform their responsibilities?

  • Do employees have access to all the appropriate systems, tools, databases, and records to perform their responsibilities and ensure compliance with recordkeeping procedures?

  • Is appropriate and specific training provided regarding recordkeeping?

  • Is the training included on an annual schedule of employee training?

  • Have appropriate parties been identified who will retain records?

  • Has the length of time for record-retention been identified?

Administrative Records

  • Commodity Classification records

  • Commodity Jurisdiction letters

  • Advisory Opinion letters

  • Copy of the Export Management and Compliance Program (EMCP)

  • BIS 748P, Multipurpose Application Form

  • BIS 748P-A, Item Appendix

  • BIS 748P-B, End-User Appendix

  • BIS 711 Statement by Ultimate Consignee and Purchaser

  • Electronic version BIS 748P, Simplified Network Application Process (SNAP) ACCN Number

  • Accompanying attachments, rider or conditions

  • International Import Certificates

  • End-user Certificates

  • License Exception TSR Written Assurance

  • AES Electronic Filing Authorization

  • High Performance Computer Records

  • Transmittal and acknowledgement of license condition

  • Log administering control over use of Export/Reexport license

  • Log maintained to ensure return or commodities previously exported under License Exception (TMP)

  • Log maintained to ensure License Exception LVS limits are not exceeded

  • Humanitarian Donations GFT Records

Transaction Records

  • Commercial Invoices

  • AES electronic filing authorization

  • Including:
    a) Description of items(s)
    b) ECCN(s)
    c) License Number
    d) License Exception Symbols or Exemptions
    e) Schedule B number(s)

  • Air Waybills and/or Bills of Lading Value of shipments

Auditing

  • Are written procedures established to verify ongoing compliance?

  • Is there a qualified individual (or auditing group) designated to conduct internal audits?

  • Is there a potential conflict of interest between the auditor and the division being audited?

  • Is there a schedule for audits?

  • Are internal reviews performed annually, every six months, quarterly, etc.?

  • Is there a step-by-step description of the audit process?

  • Is a standard audit module or self-assessment tool used?

  • Is there a written report of each internal audit?

  • Are there written results of the review?

  • Is the appropriate manager notified, if action is needed?

  • Are spot checks/informal self-assessments performed?

  • Are they documented?

  • Is there evidence of a conflict of interest between the reviewer and the division being reviewed?

  • Are records of past audits maintained to monitor repeated deficiencies?

  • Is there a “best practice” that should be shared with other divisions in the company to improve effectiveness and efficiency of export controls and promote consistency of procedures?

  • Are other departments aware of their export-control-related responsibilities, e.g., legal dept., human resources, information management, etc.?

Reporting, Escalation & Corrective Action

  • Are there internal procedures in place to notify management within the company if a party is determined to be in noncompliance?

  • Does the company policy/guidelines address accountability and consequences for noncompliant activity?

  • Are the appropriate incentives, rewards, requirements, and penalties in place and is an appropriate business culture of compliance being fostered to facilitate notification of any possible noncompliance?

  • Are there internal procedures in place to notify the appropriate U.S. Government officials (e.g., Export Administration’s Office of Exporter Services (OEXS), Export Enforcement, etc.) when non-compliance is determined?

  • Has a central corporate point-of-contact been defined for all communications with the U.S.G.?

  • Is the management chain clearly defined for Voluntary Self Disclosures (VSDs) & are there clear guidelines for VSDs?

  • Do all employees receive export control awareness training (including for potential deemed exports and hand-carry scenarios?

  • Is there a 24-hour mechanism for notifying compliance management of possible export violations or problems?

  • Does the company have an anonymous reporting mechanism for employees?

  • Do compliance guidelines provide defined criteria for when a formal internal investigation is required?

  • Do compliance guidelines include policy and procedures for follow-up reporting to management and the reporting employee?

  • Is there a process for evaluating lessons learned?

Sign Off

  • Additional Observations

  • Compliance Manager Name & Signature

  • Department Representative
  • Department

  • Name & Signature

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