No one wants to here the words, your baby is ugly. When AEI is tasked to assess a client’s compliance processes, sometimes we have to tell the client that their processes, training and personnel have a hole large enough for a violation to escape. Yes, an escape can happen at any company at any time and even the best of the best make mistakes, what I’m talking about is the poorly defined processes and total lack of communication between functions and departments that eventually leads to a huge violation.
If you are a President or General Manager here is a quick check you can run, ask your compliance officer this one question:
- What are the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability and administrative penalties for violating the Arms Export Control Act and the International Traffic in Arms Regulations that he or she must understand?
- What is Reasonable Care?
If you do not receive a firm concise answer to these questions as they relate to YOUR company and the regulations, then Your Baby is Ugly.