INTERNATIONAL TRADE LAW
International Trade Compliance Program Checklist
An international trade compliance program is the written system a company uses to follow U.S. rules on what it imports and exports — export controls, sanctions, and customs — and to prove that it did. This checklist is the umbrella over the more specific programs; it ties export controls, sanctions screening, and customs compliance into one structure with shared ownership and records.
Trade compliance fails when a company runs three disconnected efforts — an export person here, a customs broker there, no one owning sanctions. A single program with one owner closes the gaps between them.
The Three Rule Sets a Program Must Cover
Trade compliance is really three bodies of law, each with its own enforcer and its own core duty.
| Area | Enforced by | Your core duty |
|---|---|---|
| Export controls | BIS (EAR) and DDTC (ITAR) | Classify items and license controlled exports |
| Sanctions | OFAC | Screen parties; do not deal with blocked persons |
| Customs / imports | CBP | Use reasonable care in every entry |
The import side runs on a standard set by the Customs Modernization Act of 1993: CBP publishes guidance (informed compliance) and the importer owes reasonable care in declaring classification, value, and origin. The export and sanctions sides run on classification, screening, and licensing. A real program addresses all three.
The Program Checklist
Establish Ownership and Written Procedures
- Name a program owner with authority and a line to senior management.
- Document written policies and step-by-step procedures for imports, exports, and sanctions screening — not a binder, a usable workflow.
Run a Risk Assessment
- Map your real products, suppliers, customers, and destinations to trade risk.
- Identify which items are export-controlled, which markets are sanctioned, and which import flows carry classification or valuation risk.