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Independent audit of International E-Commerce’s Export Control Program
Guidepost Solutions was selected to be an independent auditor of an international eCommerce company’s export control program under an agreement with U.S. Department of Commerce. The client was at risk of millions of dollars in potential fines for alleged violations of export control regulations. The client’s attorney negotiated an agreement with the U.S. Department of Commerce where an independent audit assessing the client’s current export control program (remediated under the attorney’s guidance) would be sufficient to show compliance.
As part of the audit, Guidepost Solutions conducted a comprehensive review of the company’s export compliance program, including its policies, operations, training, screening process, and other aspects of its export control program. The audit also focused on transactions over a two-month period and presented the added challenge of reviewing documentation and policies that were routinely maintained in an Asian language.
Guidepost Solutions authored a report outlining its findings and any recommendations. The audit validated that the company’s export compliance program was robust, comprehensive, and effective in meeting U.S. export regulations. This validation enabled the client to avoid potential fines. While the program was found to be sound overall, Guidepost Solutions identified a few opportunities for improvement, including a recommendation to ensure more precise descriptions of items designated for overseas shipment.
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