Now that you have written your compliance manual and trained your team you are "compliant", right? While that is a great start, an effective Export Management and Compliance Program (EMCP) requires internal and external trade compliance monitoring and periodic audits. In fact, the BIS considers the existence and result of an internal/external audit to be one of the nine principles of effective compliance programs for great weight mitigation in BIS's administrative cases.
When was the last time you had a thorough review of your trade compliance program? Was it performed by an unbiased, independent person or by the same individual who is responsible for the success or failure of the program?
Your company's accounting auditors would have no credibility unless they performed an independent and unbiased audit of a significant sampling of your financial transactions. By the same token, you should not accept the credibility of your trade compliance program without a similarly competent and thorough audit of your import and export transactions.
