Resource & Regulatory Guidance

Overview

There are some who use the terms auditing and monitoring interchangeably. However, there is a difference. Auditing is a formal, systematic and disciplined approach that is designed to evaluate the effectiveness of a process and its related controls, then develop a corrective and preventative action (CAPA) plan to address vulnerabilities and improve processes. Audits are performed by individuals independent of the process being audited. Monitoring is an on−going process that is designed to ensure processes are working as intended

For some organizations, auditing for export controls is conducted annually where Technology Control Plans (TCPs) have been implemented, and monitoring is the actions the responsible manager for the TCP takes to ensure the TCP is being followed. While there is nothing wrong with this approach for internal processes, the auditing and monitoring for the export control department is often overlooked. Why?

Most internal auditing departments do not possess the knowledge to conduct an audit for export controls. Typically the internal audit department is focused on the financials. The export control department cannot audit themselves because they lack objectivity of their own processes and procedures. Thus, it is important that an independent party with the knowledge and skills to conduct an audit of the export compliance program be sought.

Enlisting the assistance of an independent third−party to conduct an audit of your organization’s export compliance program can be nerve wracking. However, remember that this is an approach to determine where your organization can strengthen its export compliance program and seek opportunities afforded from having a robust program. A thorough audit does take some time to perform, but done right there should be very little interruption to the organization’s day−to−day routines.

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