Export Control Audits

Why Do I Need an Audit?

Like financial audits, conducting an export control audit is a smart business strategy. An export control compliance audit allows a company to identify export control risk areas and develop a plan to tackle these problem areas. Although you may have export policies and procedures in place, there may be gaps between how things should be done and what is actually occurring. An export control compliance audit provides you analysis on gaps in your compliance system, allows you to determine the root cause of your problem, and can provide recommendations on how to improve compliance.

Can I Audit the Company Myself?

While it is possible to conduct a self-audit, it is not recommended. Although you may know your company’s policies and procedures the best, this practice risks the potential for self-blinding. Similarly, an audit by a trade compliance team within your company raises similar conflict of interest issues. While they may have the company’s best interests at heart, a trade compliance team may not want to point out faults they see within the company’s policies and procedures for fear of negative repercussions.

Best practices suggest that an independent 3rd party is better suited to conduct an export control compliance audit as they can present unbiased opinions of problem areas and suggestions for improvement. Additionally, 3rd party auditors are likely to be more familiar with identifying common risks within business units based on experience.

How Often Should an Audit Occur?

It is recommended that companies conduct an audit on an annual basis. If your company is at a higher risk of an export violation or has had persistent problem areas in the past, more frequent audits are suggested in order to pinpoint areas of weakness before they develop into a larger issue for the company.

What Does an Audit Typically Consist of?

Usually, an audit will involve three phases. The first phase is the fact finding stage. This can include interviews with staff members, reviews of transactional documents, and company policies and procedures. This first phase is often conducted onsite to garner authentic responses and impressions although preliminary exchanges of documents may occur.

The second phase is the reporting phase. Here, auditors identify gaps and inconsistencies in a detailed review of your current export control system. Based on their findings, an auditor will make recommendations to improve your export control compliance system.

The last phase is the implementation phase. With the auditor’s recommendations in mind, a company will typically develop a plan to take corrective actions to address the identified problem areas. After the corrective actions have been in place for a good amount of time, typically six months to a year, an audit is recommended in order to determine whether the corrective actions have addressed the risk areas and what works best for your company.

Tailored Approach

Regardless of project size, we collaborate with your experts to determine the best approach for your company. Usually we work remotely, using email, secure transfers, and phone conferences, but we will come to your sites if needed, typically for audits. We adhere to schedules and have the depth of expertise to keep large projects moving. In all instances, we format our reports and deliverables to your exact preferences.

Easy Procurement / Ongoing Relationship

We start with a simple engagement letter, a Non-Disclosure Agreement, and a Time Account. We work by the hour, at highly competitive rates, so you pay only for those services that you utilize. After the initial task, most of our new clients retain us on a long term/ongoing basis. Even if you don’t use CTP for months, even years, the account is left open so your access to our experts is always just a phone call away. Working with CTP Compliance is like having adjunct staff in perpetual readiness at zero cost.

How Can CTP Help?

CTP has developed a comprehensive audit tool and worked with companies to develop custom fit procedures aimed at:

• measuring company compliance against both EAR and ITAR requirements;
• gauging the efficiency and effectiveness of current procedures; and
• making prioritized recommendations to decrease risk.

Export compliance is not a “one size fits all” resolution. In a typical export control compliance audit, CTP will meet with your company to review current methodologies, documentation, and training. We evaluate the status of your export control system as a whole and look for potential risk areas for your company.
CTP’s comprehensive export control audit report will provide you with a snapshot view of where your company excels while also pinpointing challenge areas and recommend ways to strengthen your company’s export compliance program based on best practices. CTP can work with you to develop an action plan to meet your company’s needs.

For more information on conducting an export control audit, please contact Rick Phipps, Director of Commercial Business, at 703-683-5806 or rphipps@ctp.inc.com.