The Coalition for Excellence in Export Compliance (“CEEC”), a voluntary group of experienced export compliance professionals from various companies, research organizations, law firms, and consulting firms, offers for your consideration these “Best Practices” standards for export compliance programs. They are not tied to any particular country’s requirements, but rather are intended to be broadly applicable worldwide. We welcome your comments and suggestions for improving them.
While we have truly enjoyed collaborating with each other on this project, we also have found the experience quite humbling, because in drafting these standards we have learned so much about export compliance from each other. Since no one, and this includes both the private and public sectors, has yet produced a perfect set of export compliance procedures, these “Best Practices” are aspirational in nature. We understand that full compliance with them may not always be practical for all organizations, and do not expect the legal requirements to reflect these aspirational standards. But we hope you will find them to be useful as a benchmark when creating or revising your own organization’s standards.
We believe there is a need for exporters and governments to have candid discussions concerning what Best Practices exporters should follow to maximize their compliance with applicable export control laws. These discussions would be useful, not just to help greater numbers of exporters meet their legal obligations, but also to enable them to exceed the legal minimum requirements should exporters choose to do so for their own prudential reasons.
The challenges of managing export compliance are reasonably well-known. Today exporters must comply with an increasingly complex array of controls imposed by multiple governments and international organizations to address many different security and policy objectives. Export controls change rapidly in response to global events. Exporters vary greatly in size, organization, operation, and maturity, all of which can have significant implications for their compliance efforts.
Considering these factors, the CEEC members decided that, if greater compliance is to be achieved, exporters and governments should reach a consensus on a general set of best practices. To that end, we have attempted to produce a set of practices that are clear, detailed, updated, and effective for not only insuring compliance with all applicable export controls but also going beyond the minimum legal requirements.
Many benefits might flow from such a public/private consensus, including:
The documents and informational materials contained on this website are for educational and informational purposes only and represent a consensus of the individual CEEC participants based on their collective professional experience. The views expressed in these “best practices” should not be considered, in any way, as an endorsement of any standard or requirement by the individuals or the organizations with whom the individual members are associated and should not be attributed to those organizations. You should not rely on the documents and materials contained on this website as legal advice or guidance and you should consult with experienced export controls legal counsel or consultants in your jurisdiction for applicable compliance-related advice and guidance.