AUDIT STATEMENT OF WORK
Export control
compliance surveys will be performed at COMPANY NAME facilities as
mutually agreed.
Key areas to be
addressed during the survey at each of the COMPANY NAME facilities
include:
1. Do COMPANY NAME facilities
provide adequate export compliance training and awareness sufficient
to familiarize those individuals involved with the transfer in
international trade of their own and COMPANY NAME’ responsibilities
for export compliance?
2. Do COMPANY NAME facilities
maintain a comprehensive document control system that ensures no
inadvertent export of controlled goods or technology?
3. Does COMPANY NAME make
available appropriate management and legal support to the principal
personnel responsible for ensuring export compliance?
4. Does COMPANY NAME have
sufficient resources, including automated and electronic systems and
personnel, allocated to each facility for export licensing and
compliance?
5. Do COMPANY NAME facilities
have written procedures to cover:
a. Licensing Determinations &
Requirements
b. Shipping Procedures
c. Record Keeping
d. Electronic Transmissions
e. Foreign Person Activities
(Visitors and Employees)
f. Repair Returns
g.
Procurements (Domestic
and Foreign
h.
International Travel
j.
Other
Upon completion
of a comprehensive review and assessment of each facility, a report
will be provided to COMPANY NAME Legal Counsel and outside counsel,
as applicable that makes recommendations for change.
On-Site Survey
The survey will
encompass on-site review with key individuals at each of the
selected COMPANY NAME facilities.
Prior to traveling to COMPANY NAME,
request and review the following for each facility, as available:
- A pre-audit
questionnaire, that identifies the current status of the
companies export compliance activities.
- Organization
chart showing export control responsibilities
- Product
information (Brochures, Product Matrices, etc)
On-site at
COMPANY NAME facilities
- Meet with
key personnel (including but not limited to the Empowered
Official or other compliance personnel and senior staff) to
identify initial persons to be interviewed and materials to be
examined;
- Perform an
on-site survey, commencing with documentary review and including
interviews and an examination of communication/information
systems; and
- As
appropriate, provide an out-brief to management including oral
and initial written review of information from the interviews
and examinations.
Following
the on-site survey
- Prepare a
detailed final report, including specific recommendations
- Provide any
desired clarifications, and
- Be available
for follow-up discussions with COMPANY NAME management.
Deliverables
- A detailed
survey questionnaire
- As requested
by COMPANY NAME, an oral and written out-brief upon conclusion
of each on-site survey
§
A
final written report for each facility that
- details the
findings and observations, makes specific recommendations for
improvement and includes a copy of the completed survey
questionnaire that identifies the areas covered, files surveyed,
and personnel interviewed.