When it comes to trade compliance, don’t let the Justice Department make an example out of you and your company.

Build an effective trade compliance program. Here are the steps.

Step 1, get the buy-in from leadership. That means your board of directors and your senior executives.

Number 2, always do a risk assessment and update it. Look at your export and import risks, identify those that are significant.

And adopt and rebuild your policies and procedures. That’s number 3.

Number 4 is put in internal controls, make sure you identify the risks as you’re going along, and escalate for resolution.

Number 5, train. You need to train your employees to identify these issues, and there’s an annual requirement of training imposed by OFAC.

And last, audit and monitor your program, find out issues, and then improve your program overall.

This is the way we keep the Justice Department and the regulators away.

The Ethics and Compliance Q and A show is produced byOne Stone Creative.