The Role of Internal Audit in Export Controls

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes Jonathan Marks who discusses the role of internal audit in export control compliance. 

Marks starts by defining export controls and their significance: regulations governing the export, re-export, and transfer of goods, technology, and services across borders to protect national security and enforce foreign policy. As a Compliance Profession, you should recognize the severe impacts of operational disruptions, supply chain issues, and national security risks resulting from non-compliance, emphasizing the need for comprehensive compliance frameworks. Internal audit's responsibilities are expanded upon, emphasizing the necessity of robust policies, clear responsibilities, consistent employee training, and thorough risk assessments. 

Marks goes over some practical strategies for internal audit, covering the evaluation of high-risk transactions, identifying compliance gaps, regular monitoring, and testing compliance controls through transaction testing, data analytics, third-party due diligence, and incident response mechanisms. Marks underscores the importance of collaboration between internal audit, legal, compliance, and supply chain teams to ensure an integrated and proactive compliance approach, thereby mitigating risks and strengthening corporate governance.

Key Highlights 

·       Understanding Export Controls and Compliance

·       Role of Internal Audit in Export Controls

·       Key Areas for Internal Audit Focus

·       Testing and Monitoring Controls

Resources

Jonathan Marks on LinkedIn

Tom Fox

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