Implementation of a robust and sustainable Trade Compliance program is predicated on the development and adoption of standards. In the absence of well-designed standards, Trade Compliance practices and controls are disparate and disjointed. Trade Compliance Engine’s (TC Engine) Trade Compliance Standard provides companies with a comprehensive framework of capabilities, controls and requirements for implementing, managing, and maintaining an effective and efficient Trade Compliance Program.
The TCS is modeled after industry standards such as the ISO/IEC 27000 information security management systems standard. The TCS contains 11 specific Capability Categories that enable organizations to achieve compliance with export control laws and regulations. Each level within the standard provides more fine-grained requirements and guidance. The Capability Categories describe the high-level capabilities that are inherent in a comprehensive Trade Compliance program. Each Capability Category includes Control Objectives, which state what is to be achieved. Control Objectives include one or more Controls that, when implemented, enable companies to achieve the Control Objective. Each Control is supported by Implementation Guidance, which provides more detailed guidance for how requirements are to be implemented into business processes.
The Trade Compliance Framework
Conceptually, TC Engine refers to its TCS framework Temple of Compliance™. The Temple of Compliance depicts the logical order in which capabilities and controls must be implemented to establish a structurally sound TCS. The Temple of Compliance is arranged into four general capabilities categories: Groundwork, Foundational, Transactional, and Oversight.
To be effective, Trade Compliance programs must implement requirements and controls into the business. This requires Trade Compliance programs have a detailed understanding of the business, to include management structures, sites, functions, processes and systems. Many Trade Compliance programs lack this basic understanding. The TCS Groundwork Capabilities provide standardized models for capturing and managing the business landscape.
To make informed Trade Compliance decisions, Trade Compliance programs must capture, validate, maintain and make-available data points related to business partners, users, objects (products, data, software, and services), and export/import authorizations. Accurate and timely decisions require this information to be readily available to decision makers. The TCS Foundational Capabilities provide standardized models for capturing and managing Trade Compliance decision-relevant data points.
To be effective, Trade Compliance controls must be integrated into business process transactions. Integrated Trade Compliance controls result in a Trade compliance review of the transaction’s business partner, user and object attributes and decision whether these attributes are covered under an active import/export authorization. The TCS Transactional Capabilities provide a standardized model for performing Trade Compliance verification of business transactions. The standardized verification process provides repeatable and reproducible results, preventing unauthorized exports while enabling authorized exports.
To ensure ongoing effectiveness, Trade Compliance programs must monitor performance, identify gaps and continuously improve. The TCS Oversight Capabilities provide standardized models for performing assessments and audits, managing incidents, investigations, escapes and disclosures, and implementing corrective actions.