for Strategic Trade Control Compliance

Most national governments require traders to maintain complete and accurate records of their strategic trade-related activities for a specified period of time and when requested, commit to allowing designated, national authorities inspect these records. In many countries, the failure to maintain or produce STC-related records can result in penalties being imposed upon an enterprise and its employees by the national authorities.

Establishing a thorough and traceable recordkeeping system of activities involving strategic items is therefore critical to your enterprise’s STC compliance efforts. The purpose of the recordkeeping element is to ensure STC-related documents (administrative and transaction records) are maintained in a consistent manner and can be made available to your government or other external parties for inspections or audits.

Enterprises that maintain complete records of STC-related transactions enjoy benefits that extend well beyond trade compliance. Effective recordkeeping mitigates risk by allowing employees and compliance personnel to analyze trends in strategic item-related orders over a specified time period. A thorough review of your enterprise’s records could help you to recognize patterns in customers, products, end-uses, end-users, and destinations in order to gain greater insight into potentially suspicious order inquiries.

In addition, a comprehensive recordkeeping system can enable compliance officials to detect accidental STC violations during the course of audits and can facilitate cooperation with law enforcement authorities in the event of an STC-related investigation.

To implement the recordkeeping element of your ICP, your enterprise must identify what, when, by whom, and where STC-related records must be kept, so that the information is accessible and can be easily retrieved when necessary.

Implementing the recordkeeping element of your ICP requires three essential tasks:

  1. Identify the individuals responsible for maintaining STC-related records;
  2. Determine what administrative and transaction records must be kept and the required period of retention; and
  3. Create a filing and retrieval system and preferred format for maintaining and preserving STC-related records.

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