Keys to Compliance

Knowledge of Events

  Individuals, as well as the Company, may be held accountable for conduct that does not comply with the EAR, ITAR or OFAC, or other USG regulations. The definition of "knowledge" appears in the EAR. This concept applies broadly to all Export regulations. TigerSwan personnel cannot blind themselves to a possible violation, actual violation, or the misrepresentation of information submitted to the USG.

If you know of or think that a possible violation may occur or has occurred you must notify the compliance professional at once. It is very important that your organization be aware of what to do if a potential violation is about to happen, how to prevent it from happening and what to do if it does happen. Your organization will have internal disciplinary action for those employees and ICs that behave as if they have no knowledge of the regulatory environment. This training has been more than sufficient in the eyes of the U.S. Government to make you as an individual aware of the regulations and your personal responsibility. The excuse "I didn't know" is not allowed as a defense when involved in Export and Import violations — even if the person genuinely did not know — ignorance of the law only means your organization should have tried harder to train its employees and ICs and that those individuals should have tried harder to understand what their roles and responsibilities were and who to go to for assistance — prior to entering into a business transaction.