Over 1,000 standards across more than a dozen regulatory bodies.

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The most comprehensive assessment of your export compliance program

Improve compliance and gain confidence by meeting program elements matched to over 1,000 compliance program standards extracted from the U.S. Government sources listed below. Many of these standards are overlapping or duplicative, carrying added significance from repeated appearances across government sources.

AgencySourcesStandards
U.S. Department of Homeland Security2176
U.S. Department of Commerce8201
U.S. Department of Defense113
U.S. Department of Justice686
U.S. Department of State5411
U.S. Department of Treasury213
U.S. Securities and Exchange Commission28
U.S. Sentencing Commission119
Others387

U.S. Department of Homeland Security Sources

Customs and Border Protection, Importing Into the U.S. (2006).
Customs and Border Protection, Office of International Trade, Importer Self-Assessment Handbook, Appendices F and G (June 2011).

U.S. Department of Commerce Sources

Export Administration Regulations, 15 CFR 730-774 (select provisions).
Export Administration Regulations, 15 CFR § 752.11, Internal Control Programs (for Special comprehensive License) (January 1, 2015).
Bureau of Industry and Security, “Best Practices” for Industry to Guard Against Unlawful Diversion through Transshipment Trade (2011).
Bureau of Industry and Security, Export Compliance Guidelines; The Elements of an Effective Export Compliance Program (2017).
Bureau of Industry and Security, Guidance on Due Diligence to Prevent Unauthorized Transshipment/Reexport of Controlled Items to Russia (2016).
Export Administration Regulations, 15 CFR § 752.11, Internal Control Programs (for Special comprehensive License) (January 1, 2015).
Foreign Trade Regulations, 15 CFR Part 30 (select provisions).
Bureau of the Census Foreign Trade Division, Automated Export System Best Practices (August 2012).

U.S. Department of Defense Sources

U.S. Department of Defense, Defense Federal Acquisition Regulation Supplement 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting.

U.S. Department of Justice Sources

U.S. Attorneys' Manual, Corporate Compliance Programs, § 9-28.800 - Corporate Compliance Programs (November 2015).
Criminal Division Fraud Section, Evaluation of Corporate Compliance Programs (2017).
Memorandum from Deputy Attorney General Paul J. McNulty, Principles of Federal Prosecution of Business Organizations (December 12, 2006) (the “McNulty Memo”).
Memorandum from Deputy Attorney General Sally Q. Yates, Individual Accountability for Corporate Wrongdoing (September 9, 2015) (the “Yates Memorandum”).
Bureau of Alcohol, Tobacco Products and Firearms, Import Regulations, 27 CFR Part 447 (select provisions).
U.S. Department of Justice Criminal Division, Evaluation of Corporate Compliance Programs (2019)

U.S. Department of State Sources

Directorate of Defense Trade Controls, Consent Agreements (2006 to present).
DDTC Webpage
Directorate of Defense Trade Controls, Agreements Guidelines (2016).
Directorate of Defense Trade Controls, Compliance Program Guidelines (2016).
ITAR, 22 CFR (various sections)

U.S. Department of Treasury Sources

OFAC, 31 CFR 501.601
OFAC, Appendix A to 31 CFR Part 501—Economic Sanctions Enforcement Guidelines.

U.S. Securities and Exchange Commission Sources

Sarbanes-Oxley Public Company Accounting Reform and Investor Protection Act of 2002, Pub. L. No. 107-204, 116 Stat. 745 (July 30, 2002), codified at 15 U.S.C. § 7262.
U.S. Securities and Exchange Commission, Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934 and Commission Statement of the Relationship of Cooperation to the Agency Enforcement Decisions, Release Nos. SEC 44969 and AAER 1470 (October 23, 2001) (the “Seaboard Report”).

U.S. Sentencing Commission Sources

United States Sentencing Commission Guidelines Manual, § 8B2.1. Effective Compliance and Ethics Program (2016).

Others Sources

Wassenaar Arrangement: Best Practice Guidelines on Internal Compliance Programmes for Dual-Use Goods and Technologies, Elements of Internal Compliance Programmes For Dual-Use Items (2011).
Nunn-Wolfowitz Task Force Report: Industry Best Practices Regarding Export Compliance Programs (2000).
EU Guidance on Internal Compliance Programme (ICP) For Dual Use Trade Controls (2019)

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