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Export Management and Compliance Program (EMCP)
The requirements described in the Export Administration Regulations (EAR) may seem overwhelming without a system to capture analysis, decisions, accountability and implementing procedures. An EMCP takes individual decisions and pieces of information and builds them into an organized, integrated system. It is a program which can be established to manage export-related decisions and transactions to ensure compliance with the EAR and license conditions.
An EMCP can:
- Reinforce senior management commitment to comply with U.S. export laws and regulations to all parties within the company.
- Provide management structure and organization for the processing of export transactions.
- Enhance accountability for export control tasks by identifying who is responsible for performing each part of the process and who is responsible for overall effectiveness of the EMCP.
- Provide compliance safeguards throughout a company's supply chain to ensure order processing due diligence checks produce consistent export decisions.
- Provide written instructions for employees to blend into their daily responsibilities to "screen" export transactions against general prohibitions of exports, re-exports and selected transfers to certain end-uses and end-users.
- Serve as a vehicle to communicate red flag indicators that raise questions about the legitimacy of a customer or transaction.
- Provide personnel with tools to help them ensure they are performing their export control functions accurately and consistently.
- Identify transactions that could normally be exported without a license, but because of the end-use or end-user, require a license.
- Streamline the process and reduce time spent on compliance activities when employees have written instructions, tools and on-going training.
- Protect employees through training and awareness programs from inadvertently violating the EAR.
Elements of an EMCP
Obtaining EMCP Assistance
EMCP Audit Module: Self-Assessment Tool
Compliance Contacts:
For EMCP or compliance related inquiries, please contact any of the following compliance specialists in the Export Management and Compliance Division or send an email inquiry through the BIS web site system to "EMS inquiry."
Tom Andrukonis, phone 202-482-6393; email tandruko@bis.doc.gov
Renee Osborne, phone 202-482-5619; email rosborne@bis.doc.gov
Rejineta Carroll, phone 202-482-3541; email rcarroll@bis.doc.gov
Orestes Theocharides, phone 202-482-6751; email otheocha@bis.doc.gov
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