Case study: Export controls/Compliance

Facts

A German constructor of facilities is receiving an increasing number of orders from third countries and wishes to know what requirements he must comply with and implement in relation to export controls in order to secure his export business in the long term. Besides the delivery and construction of complex facilities, the company also intends to ensure the long-term supply of spare-parts which require authorisations. The company produces some spare-parts itself and procures others both at home and abroad.

Strategy

AWB will examine the status of export-related processes under German export control law as well as EU and US export control law. This begins during the development and procurement stages. The manager for development and procurement processes will be made aware of export controls and the necessity for obtaining the relevant data from suppliers. The master data file will be created using data relating to product procurement or development and the employees responsible for maintaining the data will be identified. An employee responsible for export controls will be employed at a central export control office under the person responsible for exports. The latter administers operative export controls and has the authority to stop processes and issue instructions in relation to all departments. Export controls will be incorporated into the organigramme as a staffed position.

AWB's experts will examine whether it is possible to obtain any procedural simplifications (e.g. approved exporter) and use general and collective export authorisations. Working and organisational instructions will be issued that describe the responsibilities and operations of export-related processes in detail (for example, comparing the items lists with the material master data in real-time) Software will be installed enabling the company to check the sanctions list. If there is a pending foreign trade audit, AWB will prepare the documents, ensuring that they are complete and comply with authorisations.

Success

The management informs the whole company of the need to comply with export controls and introduces measures to do so. By virtue of its consistent Internal Compliance Programme (ICP) and efficient management of authorisations, the company is able to benefit from the maximum number of simplifications as well as to quickly supply listed items reliably and on time, as spare-parts, to third countries using the relevant authorisations.