Guidance

Checklist of internal export control compliance procedures

Updated 23 December 2022

This checklist is for businesses or organisations without a central auditing function. It applies when you have an open export licence or trade licence issued by Export Control Joint Unit (ECJU).

It provides guidance on how you can:

• standardise your procedures
• follow the code of practice for export licensing

This helps you to:

• meet the terms and conditions of your export licence
• use your licence correctly
• comply with the law

Personnel records and training

You should regularly check:

• that your records of personnel involved in export control are up-to-date
• that all employees who have the ability to make exports (including everyone with access to email, telephone and fax can potentially export technology) received the necessary induction, training or retraining

Access to information

Check that staff who need it have access to:

• compliance procedures
• up-to-date legislation
• guidance notes
• contact details

Products and licences

You should regularly check:

• that any full product, country or licence matrix (or similar) is it up-to-date
• any matrix against export control legislation and current company product range (at least every 3 months)
• that control list classifications (known as ratings) of products are up-to-date, including in relation to new products or new markets
• if there been any changes to open general export licences (OGELs) in the last few months, which mean that goods or destinations are no longer covered

Customer information

You should regularly check:

• if the necessary information is reaching those responsible for licence processing (for example to ensure quick answers to end-use enquiries) - if not, sales or marketing staff should be reminded of what is needed
• if customers should be alerted to the possible need for end-use information at an earlier stage (such as on quotation documents)
• if credit control information on customers’ status is fed through for export control checks

Licence processing

You should regularly check:

• that licences held by the business are up-to-date - particularly with regard to notifying ECJU of name or address changes (bearing in mind open licences are site specific)
• that licences held by the business are valid (open individual licences must have at least 6 months before they expire) with extensions or new licences requested
• that consignee undertakings are valid and in the right format
• where individual licences are needed and that the procedure for applications is working smoothly
• that any OGELs are registered with ECJU, and the licence is quoted correctly on the relevant documentation

Exporting goods

You should regularly check that instructions to despatch department or freight forwarders:

• are up-to-date
• clearly define responsibility for documentation, including:
  • the return of any completed customs declaration for records
  • the supply of full licence details relevant to the individual export
  • the detailing of any implications (for example for routing or consolidation)
• include a final check to prevent exports without licence clearance
• are adhered to (for example copies of export documentation are returned within reasonable time)

If your procedures fail these tests you should revise or restate the requirements. Then set a date to check on improvement.

Record keeping

You should regularly check:

• 2 or 3 cases at random to see if you can access the records (required to be kept under the licences)
• that all related documents are filed together, or are accessible through common fields

Resolving problems

There must be a plan for improvements:

• if aspects of procedures are found to be unsatisfactory
• if problems are encountered in the operation of procedures
• if relevant personnel are not informed of necessary revisions or amendments