Threatening Storms of Export Compliance Program Violations for ITAR and EAR
It’s no secret that the Department of Commerce is cracking down on EAR violations. Enforcement has been regular, but has hit companies hard within the last ninety days. A corporation in the Northeast has experienced 15 violations resulting in $700,000 in fines and were related to shipments that had occurred over 5 years prior to the audit. Also, levied with aforementioned fines are thorough audits of the company’s entire export controls compliance program.
Thirteen of the fifteen violations stemmed from exporting goods without licenses, as they are controlled for national security and regional stability reasons. The two additional charges were for failing to comply with EAR record-keeping requirements. In addition to the $700,000 in fines, the company has been placed on an export denial list until the fines are paid and the audit is complete with the results submitted. The company was required to hire an unaffiliated third party consultant with expertise in the U.S. export control laws to conduct the audit.
It’s extremely important for a company to not only have an Export Compliance Program, but they must effectively establish and manage the program, tailoring it to the company while maintaining compliance with ITAR/EAR. Many companies are not aware if these regulations even apply or where to get started. Ledge Inc. leverages resources with extensive export and state department backgrounds to provide guidance, training and system development for ITAR/Export Compliance Programs, which may include site security improvements, IT infrastructure enhancements, and export licensing training.
President, Ledge Inc.
Adam is a Penn State engineer that has served as a Data Analyst and Engineer at St. Onge Company for 5 years, prior to establishing Ledge Inc. While maintaining a focus on simple solutions, Ledge Inc. has provided quality system implementation, process design, database development, quality tools, quality training, and data analysis to over 35 companies in South Central Pennsylvania and throughout the country. Adam currently serves as the sitting Chair for American Society for Quality Harrisburg Section 503 and as a member of the board for The Manufacturers’ Associations of South Central PA.
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