BPE Global Hot Topic – September 2024
Training – Your Key to the Kingdom
It’s your responsibility as a trade compliance professional to ensure all employees of your company are given training on the relevant import and export regulatory topics that affect your business. I can hear the groan from your fellow employees…but training can be fun and inspiring. It’s literally your key to the kingdom because not only do the participants gain knowledge, but you gain insight on where some issues might be occurring. Through feedback from your audience, you learn about system limitations, time and resource constraints, and other obstacles that might have nothing to do with trade compliance but everything to do with executing trade compliance.
Here are some tips for effective training techniques…
Get buy in from top management. In addition to the fact that government agencies (Bureau of Industry and Security, Directorate of Defense Trade Controls, etc.) expect all importers and exporters to have a training program in place explain and provide examples of companies that have filed voluntary self-disclosures because of a lack of training. This should inspire or at least catch the attention of upper management. If your company is large and global, you’ll want to have minimum online training such as basic export and import compliance and based on your business, perhaps sanctions, deemed exports, etc. You’ll need a budget so be prepared to prove that the trainings will be worth every penny.
Have a training strategy. You’ll want to target certain departments for different areas of compliance training. The most important part of establishing this type of strategy is that everyone who completes the training needs to have some type of ownership, accountability and the ‘tools’ to allow them to be compliant. Tools can be in the form of desk procedures and systems training that give them that ability. These types of tools get outdated quickly especially these days where new regulations seem to appear overnight. Regular audits will determine whether the trainings ‘stick’ and determine whether employees have access to these types of tools.
Know which training options will work best for your company. Many large companies use Online Learning Management Systems (LMS). These systems are easy to implement and can reach all employees. Your company might even have an LMS already that provides training on code of conduct, harassment, etc. You should be able to leverage this type of platform easily and many LMS providers have trade compliance training that can be customized. In-person training is very important for your key compliance team, Logistics, Finance, Human Resources, etc. If you can leverage an online conference platform (e.g. Zoom, MS Teams) and record it, then you can reach a larger audience now that many people work from home full or part time. Always track who completes each training as part of an audit trail.
There should be obligatory training for all employees. For instance, sanctions have been extremely confusing for multinational company. You might not even realize which departments are impacted, such as Customer Support or Engineering. Training for all may alert them to key issues they should bring to the compliance team for review. For example, we hear about occasions where an employee uses the mail room for their own benefit and ships controlled components or other parts without using the company’s ERP system for license determination. Or Support emails might be received from embargoed destinations based on the IP address. So, courses covering sanctions, compliance policies, or a review of Red Flags to look out for are helpful for everyone.
Use free resources to supplement your own personal training. There are many trade compliance association newsletters, law firm newsletters, the BIS/CBP websites, webinars and virtual events to broaden your knowledge so that you can stay on top of any new regulatory issues that might affect your company.
Here are some free government resources:
BIS
Advisories and
Seminars;
Don’t Let this Happen to You
CBP-
Webinars and
Informed Compliance Publications
Census –
Training Videos (Includes ITAR)
International Trade Administration–
Training Videos
FDA –
Learning Portal
FCC –
Events (live webcasts)
Small Business Administration –
Training for International Trade
Hopefully we’ve shed some light on this hot topic. Let BPE Global know if we can help you with any of your trade compliance needs. BPE Global is a global trade consulting and training firm. Julie Gibbs is a Director of BPE Global. You can reach Julie by email at jgibbs@bpeglobal.com or by phone at 1-415-595-8543.