Internal Compliance Program - Series (7) - Collect documentation for the Risk Assessment

Today, in the seventh article in the hands-on practical advice series on Internal Compliance Programs for Export Control: 

Part 7: Collect documentation for the Risk Assessment

You have started the Risk Assessment chapter. What background information do you need to collect ?

Your risk assessment process should start with collecting documents and information on your company's product range, customer base and business activity:

Corporate documents: 

  • Articles of association

  • Registration certificate (trade register ...)

  • List of shareholders

  • VAT number

  • Group structure chart

  • Corporate documents of parent company and subsidiaries

  • List of participations held (name of the undertaking, number of shares, ownership percentage, net equity, financial results)

  • Address of head office and locations within your country and abroad

  • Management structure, with CVs of managers

  • Annual accounts for the last 3 years

  • Description of company history (mergers, development of product range)

  • Staff statistics (total number of staff, employees involved in export related functions)

Business activity:

  • Activity reports for the last 3 years

  • Pictures of locations

  • Ongoing development projects

  • Domestic and foreign divisions/offices/facilities that have a role in export transactions

  • Description of industry sector and business model 

  • Turnover by category of activity and geographical markets

  • Field services performed

  • Steps of current order & shipping internal process

  • Document flow chart

  • General and specific terms and conditions

  • Competitors within the industry sector

Product range:

  • Product description (technical specifications), pictures and examples of for application for each product (category)

  • Products marketed by other group companies (short description)

  • Product classification under TARIC (CN nomenclature), military & dual-use lists (existing classification sheets)

  • End-use of company's products

  • Export restrictions related to company's products

Customer profile:

  • Number and description of customers within the EU and outside the EU

  • Number of shipments EU / third countries

  • Customers with repetitive sales / single transactions

  • Limitations with regard to geographical markets developed

  • Customers re-exporting products supplied to them

Country profile:

  • Description of countries of establishment of customers

  • Countries of transit

  • Countries of end-destination

  • Sanction & embargoes countries where customers are located


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