for Strategic Trade Control Compliance

As previously noted, your enterprise’s ICP is not a static instrument and it must be reviewed and amended on a regular basis. It is recommended that enterprises conduct periodic audits of their STC compliance policies and procedures in order to ensure on-going compliance with all applicable laws and regulations. The purpose of the audit element of your ICP is to appraise the integrity of your ICP – across the entire enterprise - by verifying that operational compliance procedures are being implemented properly; reflect your enterprise's stated STC compliance policies, processes, and procedures; and are consistent with all applicable STC requirements.

This requires an audit to review and assess each element of the ICP, as follows:

  • Review the management commitment statement to make sure it reflects the enterprise’s current business and STC obligations;
  • Assess the enterprise’s organizational structure to make sure lines of accountability and communication are transparent, logical;
  • Evaluate the extent to which personnel adhere to standard operating procedures (SOPs);
  • Determine whether customer and transaction screening measures are working as intended;
  • Observe order processing, transaction deliberation, and shipment processes;
  • Review the recordkeeping practices;
  • Evaluate training and instructional curricula; and
  • Assess the effectiveness of reporting mechanisms and procedures for corrective action in the event of an STC violation.


ICP audits are beneficial to your enterprise because they can reveal aspects of your enterprise’s ICP that are not working as desired and therefore require modification. They can also uncover accidental and previously undetected STC violations.

Implementing this ICP element requires your enterprise to complete the following tasks:

  1. Designate an auditor or personnel responsible for conducting the audit;
  2. Create audit modules and techniques;
  3. Establish an auditing schedule;
  4. Write an audit report; and
  5. Develop procedures for post-audit corrective actions and reporting.

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