Preparing for an Export Control Audit

Why Should You Attend:

As the party primarily responsible for adherence to all laws and regulations with respect to exported or deemed exported products, software and/or technologies, the exporter should have a robust internal control program surrounding all its import activities. However, the government does not rely solely on the exporter to be wholly compliant, and, as part of its obligations to protect national interests, has various checking measures of its own.

If you are a U S Exporter of such controlled items, it is more likely than not that, at some point, one or more interested government agencies will conduct a review of your export operations and transactional compliance. This is a serious matter and should be handled with no less care and dedication than a tax/IRS audit, with appropriate resources and guidance. An unprepared exporter can and most likely will suffer far greater penalties, up to and including loss of export privileges, and potential imprisonment of key personnel if not properly prepared. This webinar will highlight the areas of concern to help you prepare for such a review.

Learning Objectives:

• Understand the historical background,
• Identify best strategies for forming and preparing an audit team including dos and don’ts
• Performing your own proactive review of policies, procedures, transactions, and record keeping
• Identifying the role of voluntary self-disclosure and value of attorney client privilege
• Learn about managing the audit process and keeping management informed, including financial reserves

Areas Covered in the Webinar:

• History of US export control law
• Understanding the policy objectives
• Roles and responsibilities of government agencies versus the exporter
• Best practices for all areas of export/export control management
• The role of people, processes, and technology
• Serving many masters: Defending the company to the government and keeping upper management satisfied
• What to say and what not to say (or do)
• Being directed by counsel to invoke privilege and mitigate risks
• Understanding the essential aspects of your export compliance management program
• Export laws and regulations
• Roles and responsibilities including upper management support
• Cross-functional tangents
• Jurisdiction and classification (ECCN or USML)
• Destination controls
• Export license management
• Deemed exports
• Forwarder management
• Record keeping

Who Will Benefit:

• Export Compliance
• Logistics
• Supply Chain
• Legal
• Finance
• Sales
• Internal Audit
• Operations
• Engineering
• Risk Management

Randi Waltuck Barnett
Principal, International Customs Consulting

Randi Waltuck Barnett is a highly regarded global trade professional, having created and implemented global and domestic trade compliance programs across many industries for companies large and small. Her experience includes oversight of a $5B, 65-location division of Honeywell, a $3B, 17-location division of Motorola, and global trade optimization for Dell, Inc., among others.

Ms. Barnett has worked in the international trade arena in various industries for nearly 20 years. Her professional accomplishments include multi-million dollar global supply chain savings under various legal theories, as well as end-to-end global trade mitigation processes and procedures, identifying right sized technology tools, including “compliance on a shoestring” practices.

She has served on councils and boards for various organizations, including the American Association of Exporters and Importers (AAEI), the Organization of Women in International Trade (OWIT), is a charter-member of the International Compliance Professionals Association (ICPA), and a frequently sought-after trade and supply chain conference speaker for various well-known conference organizers, including the International Compliance Professionals Associations (ICPA), the American Conference Institute (ACI), Marcus-Evans, and Richardson Conference Events.

A licensed customs broker, Ms. Barnett holds degrees in International Business, an MBA in Finance, began her pursuit of a J.D. in International Trade Law; she is Lean Six Sigma Green Belt certified and a Motorola Certified Instructor, available to meet any of your trade compliance, operations or global trade strategy needs.

Topic Background:

All countries regulate the movement of goods across their borders. In most countries, this activity, for both import and exports, is governed by a customs agency or customs service. Beyond compliance with customs laws and regulations, products, software, and technology for potential export are also government-controlled if they have the potential to pose a threat to national security, provide a potential competitive advantage to countries deemed unfavorable to our own, are in potential short-supply and are possible critical to our own interests, and so on.

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