BIS's eight elements of a compliance program are explained in Export compliance program best practices. For a small or medium exporter, the question is simpler: what do we do first? Here is a practical 30-day plan.
Week 1: Know what you export
- List every product, spare part, software package and type of technical information you send abroad.
- Check jurisdiction — is anything on the U.S. Munitions List? See ITAR vs. EAR.
- Classify each item — ECCN or EAR99 — and record the reasoning. See how to find the ECCN for your product.
Week 2: Know who and where
- List your countries, customers, distributors and forwarders.
- Screen them all against the restricted-party lists. See sanctions screening.
- Flag embargoed or high-risk destinations.
Week 3: Decide licences and write the procedure
- For each product and destination pair, check the Country Chart and exceptions. See when a licence is required.
- Write a one-page procedure: classify, screen, check, record, ship — and who can stop a shipment.
- Name a responsible person.
Week 4: Train, record and test
- Train sales, shipping and engineering in an hour: what is controlled, what the red flags are, whom to ask. See red flags in export transactions.
- Set up a folder for records — classifications, screenings, licences, shipping documents.
- Run a test: take three recent shipments and check each step was done.
After day 30: keep it running
- screen before every shipment;
- classify every new product before it is sold abroad;
- review classifications when products or rules change;
- refresh training once a year;
- audit a sample of shipments every quarter.
What a small program looks like on paper
- a management statement (one paragraph);
- a product classification list;
- a one-page transaction procedure;
- a screening log;
- a records folder;
- a training record.
When to get help
Bring in an adviser for ITAR items, controlled technology and foreign employees, sensitive destinations, or any suspected violation.
Frequently asked
Do we need software for this? Not necessarily; spreadsheets work for small ranges. Tools save time as volume grows.
Do distributors' exports concern us? Yes — reexports of your products remain subject to the EAR, and red flags about distributors matter.
In ECCN.help
ECCN.help covers week 1 to week 3: the rule-based ECCN.help Classification Workflow classifies each product with the reasoning recorded, the licence check applies the Country Chart, and screening checks parties against OFAC lists. Five classifications are included with every account.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.