The goal of all good systems is incremental improvement. This is as true in export control compliance as it is in other corporate activities. Improvement doesn’t happen accidentally but rather as a result of specific steps, regularly and studiously performed. You need to periodically examine the system, identify the weaknesses, design and deploy the remedies, and then test again at regular intervals. This rigor promotes continuous evolution and it enables the system to recover from the inevitable internal and external changes that might otherwise compromise its function.
Of all these steps, the Compliance Assessment is the first and most important. You need to regularly measure your system against its baseline performance indicators, regulatory requirements, and industry best practices. Doing this enables you to determine the effectiveness of the compliance system and, most importantly, identify the gaps that need to be addressed.
The ideal plan calls for audits conducted at predetermined intervals by 3rd party experts who bring objectivity to the process. However, these reviews can be expensive and time-consuming, and few companies are willing to incur these costs as often as necessary. Fortunately, there is a nimble and affordable alternative available in the form of the internal assessment conducted by a knowledgeable company expert, typically the Export Compliance Officer (ECO).
While not a replacement for a 3rd party audit, internal assessments have two advantages that make them an excellent complementary tool: 1) they are inexpensive, and 2) they can be done swiftly. These quick looks can be revealing, exposing gaps or flaws that might otherwise go undetected for months or years. That is precisely the value of these assessments, often called Compliance Snapshots. They are not as thorough or unbiased as the 3rd party audit but the ease and speed of execution provides real-time insight.
Recognizing this value, CTP recently developed a simple, effective Diagnostic Tool to provide a snapshot assessment of your Export Compliance Program. This tool has five targeted questions in each of nine categories and the results tabulates automatically in a summary spreadsheet, where it plots the scores on a graphical display. It simple and easy to use, enabling a typical ECO to complete this Snapshot Assessment in less than an hour, providing potentially critical data almost instantly.
We have already offered this Diagnostic Tool freely to our clients and many of our collaborators. If you are an exporter who would like to try it, let us know and we’ll gladly send you a copy. We would be pleased to assist you later if the tool indicates a weakness in your compliance system but there are no obligations, costs, or strings attached. Give it a try. We think you’ll find the snapshot assessment to be a fast and effective tool.