{"id":165,"date":"2016-05-02T19:19:57","date_gmt":"2016-05-02T19:19:57","guid":{"rendered":"http:\/\/exportcompliancesolutions.com\/blog\/?p=165"},"modified":"2016-05-02T22:00:59","modified_gmt":"2016-05-02T22:00:59","slug":"export-compliance-11-words-part-3-12","status":"publish","type":"post","link":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/","title":{"rendered":"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12)"},"content":{"rendered":"

EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12):<\/strong><\/h2>\n

A SERIES ON EXPORT COMPLIANCE ESSENTIALS<\/strong><\/h2>\n

EDUCATE!<\/strong><\/h2>\n

To ensure full compliance with U.S. export controls
\nyou need to educate and train your employees<\/em><\/strong><\/p>\n

 <\/p>\n

If you are a U.S. exporter, I have four critically important questions for you:<\/p>\n

Does everyone who works for your company have a basic awareness of U.S. export laws and regulations \u2013 ITAR, EAR, OFAC Sanctions \u2013 and understand why their requirements need to be taken very seriously?<\/em><\/p>\n

Do they all know who is responsible for the company\u2019s export compliance and how to contact them?<\/em><\/p>\n

Does every employee involved in export transactions understand his or her individual compliance responsibilities clearly?<\/em><\/p>\n

Do all those employees have the appropriate competencies, skills, and resources to carry out their compliance responsibilities effectively?<\/em><\/p>\n

If you confidently answered \u201cYes\u201d to any or all of these questions, I have one more for you: How do you know that? <\/em>Unless you have a good answer for that question, scratch the previous \u201cYes\u201d answers.<\/p>\n

In the first post of this series, I said that safeguarding corporate export compliance in today\u2019s world is impossible without substantial and ongoing education and training \u2013 not just for empowered officials, export compliance managers, and licensing officers, but for every employee. I cannot emphasize this too strongly: if you are responsible for compliance with export controls in your company, you must<\/em> make employee education and training your number one priority.<\/p>\n

Number one, not number two.<\/p>\n

If I seem to be harping on this point, it\u2019s because so many companies don\u2019t seem to get it, and then end up behind the eight ball. If you won\u2019t take my word for this, there\u2019s a simple way you can see for yourself just how crucial a role employee education and training plays in assuring export compliance.<\/p>\n

Export Compliance Training: What the Fuss Is All About \u2013 and Why You Need to Know<\/strong><\/p>\n

On its web site<\/a>, the DDTC publishes copies of the final settlement documents \u2013 draft charging letters, consent agreements, remediation measures, etc. \u2013 for recent ITAR administrative enforcement cases<\/a>. A close look at exactly how the U.S. Government has dealt with these firms who were found to have committed export violations provides important information about what the DDTC expects from every company when it comes to ITAR compliance. What are the agency\u2019s foremost priorities and concerns? What types of negligence or misconduct are their investigators on the lookout for? What weaknesses or \u201cgaps\u201d in a firm\u2019s internal control processes do they consider to be especially egregious?<\/p>\n

In particular, the lists of \u201cdirected remediation measures\u201d in these settlement agreements \u2013 the specific corrective and preventive actions mandated by the DDTC \u2013 contain valuable pointers to the \u201cbest practices\u201d that every company ought to consider implementing when reviewing its compliance program.<\/p>\n

I\u2019ve examined those lists thoroughly for you, but you can peruse them for yourself, if you wish. Here\u2019s one thing you\u2019ll discover if you do:<\/p>\n

The U.S. companies involved in export violations differed greatly in size and in the products and services they exported, and the weak points in each company\u2019s compliance processes were also different. But the DDTC evidently found that their corporate export compliance programs had one major weakness in common: in practically every case, the employees had received inadequate or ineffective training on compliance with U.S. export controls.<\/em><\/p>\n

Almost every DDTC settlement letter contains language similar to the following:<\/p>\n

\u201cStrengthen compliance policies, procedures, and training<\/em><\/strong> within ___________ months of settlement, with a focus on the areas of \u00ad\u00ad\u00ad________________ .\u201d<\/p>\n

\u201cCommission an independent evaluation of the effectiveness of the training<\/em><\/strong> within prescribed timelines.\u201d<\/p>\n

\u201cImplement a formal ITAR compliance program that includes annual training<\/em><\/strong> and a compliance manual.\u201d<\/p>\n

\u201cSubmit a training program proposal<\/em><\/strong> . . . within one hundred twenty days, which includes: (a) obligations imposed by federal export laws and regulations, including disclosure obligations; (b) proper internal controls and procedures; (c) discovering and recognizing export compliance issues; and (d) obligations assumed by, and responses expected of, employees upon learning of improper or potentially illegal acts relating to export compliance.\u201d<\/p>\n

\u201cUndertake a training program <\/em><\/strong>no later than ninety days after ____________, such that all respondent employees engaged in ITAR-regulated activities are familiar with the AECA and the ITAR, and their own and respondent\u2019s responsibilities thereunder, . . .\u201d<\/p>\n

\u201cMaintain records of training programs provided<\/em><\/strong>, including the names and titles of individuals who received training, for at least five years.\u201d<\/p>\n

The examples above all come from cases published on the State Department\/DDTC web site. But BIS Export Enforcement<\/a> regularly posts similar information on how the Commerce Department has dealt with EAR violations. Don\u2019t Let This Happen to You!<\/em> \u2013 a 64-page compilation of reports on recent BIS investigations \u2013 makes for interesting and instructive, if sometimes scary, reading. If you\u2019re an export compliance officer, it ought to be on your required reading list. In addition to the multiple references to employee training \u2013 or the lack thereof \u2013 in these case reports, the BIS web site repeatedly spotlights \u201congoing compliance training<\/strong> and awareness\u201d as one of the Nine Key Elements of an Effective Export Compliance Program<\/em><\/a>, and includes \u201cadequate training<\/strong> provided to employees\u201d on its short list of Export Enforcement Mitigating Factors<\/em>.<\/p>\n

OFAC Enforcement<\/a> also publishes the details of selected settlement agreements on the Treasury Department web site<\/a>. Those OFAC reports belong on your required reading list as well. [Content Warning: A few of these agreements and enforcement reports contain high settlement amounts and penalties that some compliance officers may find disturbing. EOs and ECOs are advised to sit down before reading.<\/em>] In each case, OFAC explains how they decided the appropriate penalty for the company, explicitly stating which findings their investigators considered to be \u201cmitigating factors,\u201d \u201caggravating factors,\u201d or (in some cases) evidence of \u201creckless disregard.\u201d Since the Treasury Department has taken great pains to provide you with this extremely useful information, wouldn\u2019t it be wise to read it carefully . . . with a pencil or yellow highlighting pen in hand?<\/p>\n

In case after case, you\u2019ll see poor (or non-existent) compliance training cited as a significant contributing cause of the violations. In settlement after settlement, you\u2019ll find phrases and sentences similar to these:<\/p>\n

\u201cFailing to provide training<\/em><\/strong> to its employees regarding export controls and sanctions\u201d<\/p>\n

\u201cCompliance program did not include any training<\/em><\/strong> on OFAC regulations\u201d<\/p>\n

\u201cFailed to adequately train<\/em><\/strong> its employees\u201d<\/p>\n

\u201cTraining is sporadic<\/em><\/strong> and does not cover important regulatory and risk areas\u201d<\/p>\n

Question: What effect do you think those findings had on the severity of the penalties that OFAC assessed?<\/p>\n

On the other hand, in a recent case in which some rather serious sanctions violations occurred, OFAC highlighted their investigators\u2019 finding that the company\u2019s employees had received \u201cf<\/strong>requent training, including in-person training by high-ranking persons within the organization<\/strong>,\u201d and laid the principal blame for the violations on a \u201crogue employee,\u201d who was found to have made extensive efforts to evade the firm\u2019s internal controls. In this instance, the presence of a robust compliance education and training program (note well: with senior management commitment and involvement!<\/em>) unquestionably helped save a company from potentially serious damage.<\/p>\n

So, why do I keep underscoring the importance of employee education and training in a corporate export compliance program? Because all the U.S. Government regulatory agencies have made it plain that their agents will look at this element closely, and they keep warning us that they consider it to be both a critical factor in preventing export violations<\/em> and a reliable measure of the seriousness of your commitment to compliance<\/em>.<\/p>\n

\u201cEducation\u201d vs. \u201cTraining\u201d: What\u2019s the Difference?<\/strong><\/p>\n

Education<\/em> and training<\/em> are usually thought of as synonyms, and it is true that they are often used interchangeably. But the terms can be distinguished, and in some contexts the difference between them is far from negligible or irrelevant. The University of Pennsylvania, for example, is proud of its Department of Criminology, where students can get an education<\/em> about crime that prepares them to deal with criminals and understand the U.S. justice system. The university would probably sue you for defamation, however, if you went around calling their campus a \u201ctraining<\/em> ground for crime\u201d! Here\u2019s another example: as some wag has said, when parents are asked to sign a consent form to allow their child to participate in sex education<\/em> classes at a public school, they generally understand this to mean something different from sex training.<\/em><\/p>\n

Education<\/em><\/strong> is helping someone understand<\/em><\/strong> something. It\u2019s about learning the theory; gaining insight into principles of a subject; being able to see the Big Picture and distinguish between the essentials and the details; understanding well enough to analyze, think critically, make judgments, and share your understanding with others. That\u2019s always been the rationale for education in the traditional professions. Lawyers need a legal education<\/em> \u2013 a thorough understanding of the principles of law and how the U.S. legal system operates \u2013 before they start offering legal services to the public or defending clients in the courtroom. Surgeons need a medical education<\/em> \u2013 a solid grasp of anatomy, physiology, biochemistry, and many other medical subjects before they pick up a scalpel.<\/p>\n

Training<\/em><\/strong> is showing someone how to do<\/em><\/strong> something; it\u2019s about acquiring the practical skills and competencies needed to carry out a specific task. A training program<\/em> is designed for people who need the know-how they will acquire in order to perform their jobs more effectively or solve certain problems they are facing. \u00a0When employees are charged with implementing a new system, they will generally need training that will equip them to do it. Because training focuses on practical knowledge, it normally involves learning-by-doing, coaching or mentoring by an expert practitioner, hands-on practice, drill, and repetition, as well as ongoing feedback with a view to improving performance. That\u2019s why surgeons and lawyers are required to supplement their law school or medical school education<\/em> with a period of training <\/em>\u2013 \u00a0as an intern, resident, or associate \u2013 before they can be licensed and admitted to their professions.<\/p>\n

\u201cEducation\u201d vs. \u201cTraining\u201d: Which Is More Important?<\/strong><\/p>\n

When it comes to corporate export compliance, which of the two is more important\u2014education or training? The best answer, of course, is that both are equally vital.<\/p>\n

For employees at all levels, a mandatory program of company-wide export compliance awareness education<\/em> will supply the necessary background and lay the groundwork for subsequent practical training<\/em> in specific skills and competencies. This kind of foundational understanding throughout the company is essential, because the actions of all your employees can have a great impact on the effectiveness of your company\u2019s compliance program \u2013 positive or negative.<\/p>\n

Employees in departments such as human resources, public relations, purchasing, accounting, engineering and design, research and development, manufacturing, quality assurance, information technology, sales and marketing, logistics, planning, maintenance, shipping, and customer service could inadvertently cause the company to violate U.S. export laws and regulations, even if their jobs do not involve export transactions and even if they never have occasion to interact directly with foreign customers. These employees need to have an awareness of and basic education<\/em> about U.S. export controls \u2013 their rationale, their scope, how they operate, how they impinge on the company\u2019s business, which company officials are responsible for ensuring compliance, and other matters \u2013 so that they can recognize potential issues and avoid careless violations.<\/p>\n

Managers and administrators who are responsible for planning and goal-setting, risk analysis and mitigation, compliance decision-making, and program development need a more advanced education<\/em> in export controls and a wide range of related issues in order to do their jobs effectively and safeguard compliance.<\/p>\n

All these employees, whatever their responsibilities or level in the organizational hierarchy, will also need hands-on, experiential training<\/em> \u2013 via live seminars, interactive lecture-demonstrations, small discussion groups, workshops, case studies, example scenarios, role-playing, on-site one-on-one instruction, personal coaching\/mentoring, and other modalities \u2013 to acquire the practical skills and competencies specific to their jobs.<\/p>\n

The following examples may help you see how education and training can be distinguished from one another. The lists below are by no means complete; these topics are just a sample of the kinds of knowledge, information, and practical skills your employees need in order to safeguard full compliance with export controls. But I hope these examples will persuade you that both<\/em> education and<\/em> training are essential to mitigate the risk of export violations and build a successful corporate export compliance program.<\/p>\n

Export Compliance \u201cEducation\u201d Topics<\/em><\/strong>
\n(\u201cabout\u201d knowledge, understanding what the regulations are, insight into how the agencies work, awareness of company policies & job responsibilities) <\/em><\/p>\n

Overview of the U.S. Export System<\/em><\/p>\n

Licenses & Export Authorizations Under the ITAR<\/em><\/p>\n

Licenses & Export Authorizations Under the EAR<\/em><\/p>\n

Understanding OFAC Sanctions Programs & the SDN List<\/em><\/p>\n

Understanding the CCL: Categories, Product Groups, ECCNs<\/em><\/p>\n

The Role of the Empowered Official<\/em><\/p>\n

Risk Assessments & Compliance Audits<\/em><\/p>\n

Deemed Exports & the Hiring of Foreign Nationals<\/em><\/p>\n

Cybersecurity & Export Compliance<\/em><\/p>\n

Export Compliance Issues in Mergers & Acquisitions<\/em><\/p>\n

Current Export Enforcement Trends<\/em><\/p>\n

Export Control Reform: Recent Developments<\/em><\/p>\n

Export Compliance \u201cTraining\u201d Topics<\/em><\/strong>
\n(\u201chow-to\u201d knowledge, specialized skills, practical expertise, ability to perform specific tasks, use relevant software & available resources, identify potential issues)<\/em><\/p>\n

How to Fill Out a DSP-5 License Application<\/em><\/p>\n

Classifying a Commodity<\/em><\/p>\n

Identifying Encryption Items<\/em><\/p>\n

Filing a Shipment in the Refactored AESDirect System<\/em><\/p>\n

How to Recognize Export Control \u201cRed Flags\u201d<\/em><\/p>\n

Marking of Documents That Contain ITAR-Controlled Data<\/em><\/p>\n

Compliance with EAR & ITAR Recordkeeping Requirements<\/em><\/p>\n

Steps for Performing a Restricted Party Screening<\/em><\/p>\n

Visitor Access, NDAs, & Escort Procedures<\/em><\/p>\n

How to Submit a Voluntary Disclosure<\/em><\/p>\n

Drafting a Technical Assistance Agreement<\/em><\/p>\n

In the next post of this blog series on export compliance essentials, \u201cCLASSIFY!\u201d we\u2019ll discuss the importance of properly identifying and classifying the categories of products, services, and technical data that are subject to export controls and understanding the regulatory requirements that apply to each category.<\/strong><\/p>\n","protected":false},"excerpt":{"rendered":"

EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12): A SERIES ON EXPORT COMPLIANCE ESSENTIALS EDUCATE! To ensure full compliance with U.S. export controls you need to educate and train your employees   If you are a U.S. exporter, I have four critically important questions for you: Does everyone who works for your company have […]<\/p>\n","protected":false},"author":4,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"nf_dc_page":"","footnotes":""},"categories":[7,11],"tags":[],"class_list":["post-165","post","type-post","status-publish","format-standard","hentry","category-all","category-education-and-training"],"yoast_head":"\nEXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions<\/title>\n<meta name=\"description\" content=\"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions\" \/>\n<meta property=\"og:description\" content=\"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training\" \/>\n<meta property=\"og:url\" content=\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\" \/>\n<meta property=\"og:site_name\" content=\"Export Compliance Solutions\" \/>\n<meta property=\"article:published_time\" content=\"2016-05-02T19:19:57+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2016-05-02T22:00:59+00:00\" \/>\n<meta name=\"author\" content=\"Export Compliance Solutions\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Export Compliance Solutions\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"12 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/#article\",\"isPartOf\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\"},\"author\":{\"name\":\"Export Compliance Solutions\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/67ff29bf0564dfc7e76544292c11dcb9\"},\"headline\":\"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12)\",\"datePublished\":\"2016-05-02T19:19:57+00:00\",\"dateModified\":\"2016-05-02T22:00:59+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\"},\"wordCount\":2307,\"commentCount\":0,\"publisher\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#organization\"},\"articleSection\":[\"All\",\"Education and Training\"],\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"CommentAction\",\"name\":\"Comment\",\"target\":[\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/#respond\"]}]},{\"@type\":\"WebPage\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\",\"url\":\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\",\"name\":\"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions\",\"isPartOf\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#website\"},\"datePublished\":\"2016-05-02T19:19:57+00:00\",\"dateModified\":\"2016-05-02T22:00:59+00:00\",\"description\":\"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training\",\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/\"]}]},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#website\",\"url\":\"https:\/\/exportcompliancesolutions.com\/blog\/\",\"name\":\"Export Compliance Solutions\",\"description\":\"\",\"publisher\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/exportcompliancesolutions.com\/blog\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#organization\",\"name\":\"Export Compliance Solutions\",\"url\":\"https:\/\/exportcompliancesolutions.com\/blog\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/logo\/image\/\",\"url\":\"https:\/\/exportcompliancesolutions.com\/blog\/wp-content\/uploads\/2015\/09\/ecs_logo.png\",\"contentUrl\":\"https:\/\/exportcompliancesolutions.com\/blog\/wp-content\/uploads\/2015\/09\/ecs_logo.png\",\"width\":226,\"height\":113,\"caption\":\"Export Compliance Solutions\"},\"image\":{\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/logo\/image\/\"}},{\"@type\":\"Person\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/67ff29bf0564dfc7e76544292c11dcb9\",\"name\":\"Export Compliance Solutions\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/image\/\",\"url\":\"https:\/\/secure.gravatar.com\/avatar\/fb63828a9af2d663044d4b4f3b70b09291b2ff872bf165b3fad5dada75698fb1?s=96&d=mm&r=g\",\"contentUrl\":\"https:\/\/secure.gravatar.com\/avatar\/fb63828a9af2d663044d4b4f3b70b09291b2ff872bf165b3fad5dada75698fb1?s=96&d=mm&r=g\",\"caption\":\"Export Compliance Solutions\"},\"url\":\"https:\/\/exportcompliancesolutions.com\/blog\/author\/export-compliance-solutions\/\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions","description":"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/","og_locale":"en_US","og_type":"article","og_title":"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions","og_description":"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training","og_url":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/","og_site_name":"Export Compliance Solutions","article_published_time":"2016-05-02T19:19:57+00:00","article_modified_time":"2016-05-02T22:00:59+00:00","author":"Export Compliance Solutions","twitter_card":"summary_large_image","twitter_misc":{"Written by":"Export Compliance Solutions","Est. reading time":"12 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/#article","isPartOf":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/"},"author":{"name":"Export Compliance Solutions","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/67ff29bf0564dfc7e76544292c11dcb9"},"headline":"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12)","datePublished":"2016-05-02T19:19:57+00:00","dateModified":"2016-05-02T22:00:59+00:00","mainEntityOfPage":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/"},"wordCount":2307,"commentCount":0,"publisher":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/#organization"},"articleSection":["All","Education and Training"],"inLanguage":"en-US","potentialAction":[{"@type":"CommentAction","name":"Comment","target":["https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/#respond"]}]},{"@type":"WebPage","@id":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/","url":"https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/","name":"EXPORT COMPLIANCE IN 11 WORDS (Part 3 of 12) - Export Compliance Solutions","isPartOf":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/#website"},"datePublished":"2016-05-02T19:19:57+00:00","dateModified":"2016-05-02T22:00:59+00:00","description":"To safeguard compliance with the ITAR, EAR, & OFAC Sanctions and prevent export violations, U.S. exporters must prioritize employee education & training","inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/exportcompliancesolutions.com\/blog\/2016\/05\/02\/export-compliance-11-words-part-3-12\/"]}]},{"@type":"WebSite","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#website","url":"https:\/\/exportcompliancesolutions.com\/blog\/","name":"Export Compliance Solutions","description":"","publisher":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/#organization"},"potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/exportcompliancesolutions.com\/blog\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#organization","name":"Export Compliance Solutions","url":"https:\/\/exportcompliancesolutions.com\/blog\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/logo\/image\/","url":"https:\/\/exportcompliancesolutions.com\/blog\/wp-content\/uploads\/2015\/09\/ecs_logo.png","contentUrl":"https:\/\/exportcompliancesolutions.com\/blog\/wp-content\/uploads\/2015\/09\/ecs_logo.png","width":226,"height":113,"caption":"Export Compliance Solutions"},"image":{"@id":"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/logo\/image\/"}},{"@type":"Person","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/67ff29bf0564dfc7e76544292c11dcb9","name":"Export Compliance Solutions","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/exportcompliancesolutions.com\/blog\/#\/schema\/person\/image\/","url":"https:\/\/secure.gravatar.com\/avatar\/fb63828a9af2d663044d4b4f3b70b09291b2ff872bf165b3fad5dada75698fb1?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/fb63828a9af2d663044d4b4f3b70b09291b2ff872bf165b3fad5dada75698fb1?s=96&d=mm&r=g","caption":"Export Compliance Solutions"},"url":"https:\/\/exportcompliancesolutions.com\/blog\/author\/export-compliance-solutions\/"}]}},"_links":{"self":[{"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/posts\/165","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/users\/4"}],"replies":[{"embeddable":true,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/comments?post=165"}],"version-history":[{"count":7,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/posts\/165\/revisions"}],"predecessor-version":[{"id":172,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/posts\/165\/revisions\/172"}],"wp:attachment":[{"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/media?parent=165"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/categories?post=165"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/exportcompliancesolutions.com\/blog\/wp-json\/wp\/v2\/tags?post=165"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}