The Jurisdiction, Classification & Marking (JCM) Challenge
Jurisdiction, Classification & Marking (JCM) are critical capabilities in a compliance program. Export jurisdiction and classification define how an “object” (e.g. hardware, software, technical data and services) must be controlled, including the legal means of exporting the object. In the absence of dependable and readily available jurisdiction and classification determinations, the only way to achieve export compliance is to prevent exports.
Historically, the “export prevention” approach has focused on enforcing export shipment controls. For example, if an object had not been classified at time of shipment, the shipment would be blocked until export classification could be determined. Once triggered, the export classification process involved regulatory Subject Matter Experts (SMEs) manually collecting information about the object, reviewing regulations and making a one-off, regulatory interpretation based on tribal-knowledge.
Although physical shipping controls remain an integral part of an export compliance program, in today’s globally-networked, information-driven economy, the risk of unauthorized exports has shifted to information and Information Technology (IT) systems. In an era of nationally diverse workforces, globally distributed supply chain, international marketplaces, and shared IT resources, the traditional approach to export compliance and JCM is woefully inadequate. A new approach and new capabilities are needed. To meet today’s export compliance needs, JCM capabilities must be standardized, automated and integrated with the business systems where information is being created, stored, and shared.
Meeting the JCM Challenge
To meet the JCM challenge, TC Engine has developed a software product that enables the jurisdiction and classification process to be standardized through the creation and use of decision trees. The decision trees institutionalize regulatory interpretations for commodities, product lines, etc. The decision trees provide a guided, automated experience that allows personnel to arrive at accurate jurisdiction and classification decisions by answering questions about the objects being classified. This capability is unique as it allows the JCM effort to be distributed to personnel who are knowledgeable about the product, but not regulatory SMEs. In cases where a jurisdiction of classification cannot be easily reached, the decision trees enable escalation to a regulatory SME.
Additionally, the JCM tool is designed for integration. Through standardized interfaces, the tool can be connected to business systems to collect object information and return jurisdiction and classification attributes. Integration allows classification to be embedded in the business systems, enabling compliant data creation, storage and sharing.
- Object Database – The ability to keep visibility into the number of objects (hardware, technical data, software, and services) that have not been assigned a classification.
- Classification Request – The ability to create new objects and/or request the classification be completed for existing objects.
- Express Classification – The ability to search the regulatory content and assign an object a classification. Provide justification for the classification determination, including text, attachments, and weblinks. Provides the ability to search the object database for completed classifications and classify by similarity.
- Guided Classification – The ability to use commodity based questions to guide a user to a completed classification. This functionality allows for the automation of the classification process by creating custom decision trees to assist users in driving to a consistent classification determination.
- Mass Classification – The ability to classify or reclassify more than one object at a time.
- Classification Recordkeeping – The ability to record and store classification determinations in a single repository.
- Classification Workflow – The ability for Trade Compliance trained subject matter experts (SME’s) to review and approve classification determinations completed by other users.
- Classification Collaboration – The ability for a user to collaborate live through instant chat messaging with additional personnel to assist in the classification process.
- Classification Revision History – The ability to document and store revisions of completed classification determinations.
- Import Completed Classifications – The ability to import completed object classification records.
- Export Completed Classifications – The ability to export/extract completed object classification records into a CSV file.
- Application Program Interface – The ability to connect any field within the software to any business system employed by a customer.
Classification Types – The ability to assign a classification decision for U.S. export control (ITAR and EAR), Harmonized Tariff Schedule (HTSUS), Schedule B Number, and UNSPSC content types. The software is designed to be content agnostic, meaning that to allow for additional classification types the content simply needs