Tagged: trade compliance

Episode 77 — Implementing an Effective Trade Compliance Program

Companies involved in export and import activities face a variety of risks from sanctions and export controls created by a complex maze of regulations and oversight from the Department of State, Department of Treasury and the Department of Commerce.  With the increasing complexity of sanctions regimes, companies have to devote significant attention and resources to implement an effective trade compliance program. In this episode, Michael...

Merging Trade Compliance and Ethics and Compliance Silos

Business operations can be riddled with inefficiencies.  It is easy to spot them inside a company.  The same rule applies to ethics and compliance programs.  Given a specific global business configuration, ethics and compliance programs have to be designed efficiently to support the business.  For some reason, a number of compliance programs have been built with two separate silos – one for trade compliance and...

FLIR Systems ITAR Settlement Outlines Important Export Compliance Factors (Part II of II)

The FLIR Systems settlement is an extraordinary event given the sheer number of violations, the systemic breakdown that occurred, and the absence of any meaningful compliance controls.  It is all the more surprising given the fact that FLIR’s operations are devoted in large proportion to the highly-regulated international defense industry market.  Given the level of risk, you would expect FLIR to have in place systems...

FLIR Systems Pays $15 Million Civil Penalty for AECA and ITAR Violations and Earns First DTCC Monitor (Part I of II)

In an extraordinary enforcement action, the US Department of State reached a comprehensive settlement with FLIR Systems, Inc. (FLIR) to resolve violations of the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR).  These acts are administered by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs (DTCC). Under the settlement, FLIR will pay a civil penalty...

Cuba and Iran Export Compliance

I recently published an article on Trade Ready concerning export compliance and recent sanctions developments in Cuba and Iran.  A link to the article is here. Thanks for your continued support.