Standard Licensing

Recordkeeping and Reporting
Detailed Documentation

 Companies are required to keep records on all transactions relating to imports and exports, this includes every time technical data is transferred - no matter what format - if you e-mail 20 manuals to a foreign party over a period of four months, each of those e-mails must be documented and filed with the authorization to allow for quick determination of what exports have been made in furtherance of, or in support of your approval. For some companies that have engineers or other personnel that work daily with foreign parties, this requires each person keep a phone, fax, and e-mail log that records the time, date, what was exported, to whom, and several other factors. Recordkeeping requirements can be incredibly burdensome and yet, they still must be managed. The laws are very clear in this aspect of Export and Import regulations. For companies that provide defense services, such as training classes, class rosters, curriculum, time, dates, locations, etc. must be recorded for every class - sometimes daily.

Companies are required to keep full records of every shipment they make to a foreign entity, including the Air Waybills and other export documentation. Any time a foreign visitor comes to your organization, a record of that must be kept, any time a foreign national has access to your computer systems, it must be recorded (and confirmation that authorization was in place for that foreign person to access anything that may be considered technical data on your system).

These are just a handful of examples of required records - a review of the regulations will demonstrate that there are hundreds of required documents, reports, authorizations, etc. that must be maintained in order to be compliant.

Your compliance professional may ask you to keep logs, print out documentation, develop an electronic storage system, or some other method for maintaining copies of the enormous number of records that must be kept related to international business. This one issue seems to be the biggest item individuals struggle with, in truth, it is a hassle and difficult to get into the habit of creating these records and files each day. The temptation to put it off is huge. A word of caution on that behavior - some organizations that have had requests for the presentation of records from the U.S. Government have literally spend millions of dollars and thousands of man hours attempting to recreate the records that should have been there all along - a failure to be able to produce records gives those U.S. Government Regulatory agencies a negative opinion of your organization - and that is something you cannot afford. Your organization must be considered willingly compliant and anxious to do the right thing. This is vital to your applications getting approved, your shipments being allowed to export and your ability to win other U.S. Government contracts - as well as avoid millions of dollars in fines and legal fees.