Standard Licensing

Recordkeeping and Reporting

  Of all the concepts discussed in this training, recordkeeping is among the most important. It is vital to the survival of your organization that you keep complete and accurate records of pretty much anything that has to do with Foreign Nationals, imports or exports.

Both the Department of State and the Department of Commerce (as well as the other regulatory agencies) have very detailed requirements (and lengths of time records must be kept) relating to recordkeeping. Records vary in their retention time (from 5 years to 25 years) and TigerSwan will keep those records in its corporate office. Employees and ICs do not have the authorization to destroy any records.

Organizations are required to keep records in an easily accessible and legible format. All records must be kept in an organized fashion and must be complete with copies of all required documents per the Import and Export regulations. In addition to records, there are strict reporting requirements that must be adhered to as well. Many of those reporting requirements have different timelines and must be tracked closely — some are monthly, every six months, once a year and so on.

Government agencies with import and export compliance responsibilities may request export— or import-related documentation with short lead times (sometimes less than 24 hours). A failure to produce full records or reports is considered a violation, even worse, for each required document that is not in the file, an additional violation is added. Recordkeeping is easily one of the biggest ways to avoid enormous fines and penalties and one of the easiest ways to incur huge fines and penalties. U.S. Government regulations impose strict recordkeeping and reporting requirements.

This can only be done if your organization keeps strict control over its files and documents everything related to an Import and Export transaction or interaction with Foreign Nationals or entities. You will be required to keep logs, inventories or reports related to your duties as an employee or IC.

Recordkeeping can be almost a full time job and it is the responsibility of every position within an organization to keep those records. Every organization struggles with how to best maintain their records. There is enormous temptation to place the responsibility on a single individual that cannot possibly keep full and accurate records of all the transactions each of your employees are involved in. It is very important that you keep full and accurate records of all activities you engage in as a TigerSwan employee or IC. Your Program Manager will provide detailed instructions as to what records you will be specifically required to maintain. These records must be complete and filled in as soon as the activity is complete — do not wait and try and reconstitute records after the fact. It is important that these records are 100 percent accurate as well — otherwise they could be considered a submission of false documents to the U.S. Government. This could result in criminal charges being brought against TigerSwan or the individual IC involved. To avoid this — keep your records up to date and accurate and provide them on a regular basis to Tom Wright for him to manage the export regulations recordkeeping requirements.