Looking for someone to conduct a gap analysis of your trade compliance activities? Consultants come in all shapes and sizes, with various backgrounds, skills and expertise. But not all consultants (or their assessments) are created equal! Before you give that consultant a green light, make sure you have a thorough understanding of what they'll be looking for, and how they'll be doing it. In other words, you need to feel confident that they have the expertise – and the process – to conduct a meaningful assessment.
Whether it’s a formal audit, preparation for a U.S. government “visit,” or what we refer to as a “gap analysis,” your trade compliance consultant needs access to the people who can answer questions and provide the necessary information to paint an accurate picture of your compliance activities. It’s best to have your auditor accompanied by the one or two employees who are primarily responsible for trade compliance in your organization. Encourage your team to take notes during the visit, so they can compare these to the observations, findings, and action items contained in the gap analysis report.
Here's a list of nine components that should be addressed in every export compliance gap analysis. (Hint: If your consultant doesn't cover these, you may want to look elsewhere.)
- Visitor Sign-In
- Hiring Practices
- Business Development and Marketing
- Classification of Items
- Contract Creation and Management
- Purchasing/Supply Chain
- Manufacturing, Assembly and Inspection
- Shipping/Receiving/AES Filings
- Record Keeping
If, at the end of the assessment, it is discovered that any required exporting or domestic shipping information is missing, inconsistent, or incorrect, then a good consultant would have already looked all throughout the process for gaps and come up with some ideas on how to fix them.
I realize this list oversimplifies the process to a certain degree. There may be a variety of other departments and job functions that should be part of your company’s gap analysis. Hopefully, this list gives you a good place to start when you’re evaluating candidates to help you improve.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.