Basics of Conducting U.S. Export Control Compliance Audits

Compliance with US export controls and sanctions laws has increasingly become a focus of both US and non-US based companies in recent years. Savvy companies recognize that the US export and sanctions regime applies not only to US companies and activities that take place within the United States, but that it also has extraterritorial implications for many non-US companies and activities that take place outside of the United States. Therefore, it is critical that all companies subject to US export controls and sanctions – including those outside of the United States - maintain export compliance programs and routinely audit their effectiveness, while paying special attention to the added level of complexity that results from the interjurisdictional dimension of compliance with US laws. This article outlines the basics of conducting US Export Control Compliance Audits.