HighCom Armor management is firmly committed to full and complete compliance with all U.S. export control laws, including among others, the Export Administration Regulations administered by the Bureau of Industry and Security of the U.S. Department of Commerce, the International Traffic in Arms Regulations administered by the Directorate of Defense Trade Controls at the U.S. Department of State, and the various sanctions and embargo regulations administered by the Office of Foreign Assets Controls (OFAC) at the U.S. Department of the Treasury.
Our Export Management Control Program serves as a general reference for the procedures to be followed during the export and transportation of goods by HighCom Armor, which is subject to U.S. export laws and regulations. This Manual is an educational tool. It sets out procedures in general terms with a view to assuring that all HighCom Armor personnel who are responsible for export-related functions will have a clear understanding of how their responsibilities contribute to HighCom Armor’s compliance with the export laws, regulations, and policies.
The written procedures exist for appropriate shipping authorizations, as well as assists in determining if:
- a license is required,
- a license exception is eligible (specify which),
- no license is required (NLR.)
Trade compliance is a vital component of any global business. It’s everyone’s responsibility and in all our interests to comply with the requirements.
- Effective trade compliance safeguards national security and keeps the country safe from terrorism
- Provides compliance safeguards throughout a company’s supply chain to ensure consistent export decisions, reliable order processing, and thorough due diligence.
- To ensure that the goods are classified correctly, origin, and valuation of goods are accurately declared in accordance with the laws and regulations and that the appropriate duties and taxes are paid.
- Serve as a vehicle to communicate red-flag indicators that raise questions about the legitimacy of a customer or transaction.
- Protect employees, through training and awareness programs, from inadvertently violating the EAR & ITAR regulations
- To protect critical goods, technology and information from falling into the wrong hands
- Risk Assessments
- Handling export violations & taking corrective actions.
An effective trade compliance program protects the company and country from potential danger by screening new vendors, customers, and visitors; applying for licenses to import and export goods; and ensuring that all requirements are met regarding exports and imports.
WHAT ARE THE REGULATIONS?
- Controls all commercial items
- Licenses not always required, need classification & destination to determine
- Controls any item specifically designed/modified for military use/application
- Licenses required, few exemptions
WHO ARE THE REGULATORS?
- Relates to military and defense articles and services, designed or configured for military applications, with no equivalent civilian or commercial products.
- Controlled items found on the U.S. Munitions List.
- Relates to “dual-use” civilian and military items, information, or software.
- Controlled items found on the Commerce Control List.
- Administers and enforces economic and trade sanctions.
Employees that have both the conscience and confidence to step forward when actions are suspect are one of the best defenses a company has to minimize the risk of noncompliance!
HighCom Armor performs screening on all parties (to the export transaction against the U.S. proscribed parties lists) prior to exporting. Screening is performed at the initial time an order comes in and subsequently prior to export.
We take screening seriously and act accordingly when there is a potential screen hit, license determination concern or question, or the presence of a red flag or questionable transaction.
HIGHCOM ARMOR EXPORT COMPLIANCE LIFECYCLE
Screening revolves around red flag indicators apart from screening the consolidated party-list provided by USG.
RED FLAG INDICATORS
- The customer or its address is similar to one of the parties found on the Commerce Department’s [BIS’] list of denied persons.
- The customer or purchasing agent is reluctant to offer information about the end-user of the item.
- The product’s capabilities do not fit the buyer’s line of business, such as an order for sophisticated computers for a small bakery.
- The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.
- The customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing.
- The customer has little or no business background.
- The customer is unfamiliar with the product’s performance characteristics but still wants the product.
- Delivery dates are vague, or deliveries are planned for out of the way destinations.
- A freight forwarding firm is listed as the product’s final destination.
- The shipping route is abnormal for the product and destination.
- When questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, for export, or for reexport.
If there are no “Red Flags” we proceed with a transaction in reliance on information we have received.
Review “Know Your Customer Guidance” for the complete list of Red Flag Indicators.
HIGHCOM ARMOR IS PROUD TO ANNOUNCE TRACE CERTIFICATION!
TRACE Certified companies are “pre-vetted” partners for multinational companies seeking to do business with suppliers, agents, and consultants who share their commitment to commercial transparency.
HighCom Armor has completed a comprehensive due diligence process administered by TRACE, the world’s leading anti-bribery standard-setting organization.
WHAT IS TRACE
TRACE is the world’s leading anti-bribery standard-setting organization and is widely recognized in the international business community. TRACE International is a 501c(6) non-profit business association founded in 2001 to provide multinational companies and their commercial intermediaries with anti-bribery compliance support.