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Import and Export Compliance Expertise

 

Since its inception in 1986, GTS has dedicated significant resources to build, implement and maintain an effective Compliance Management Program that integrates all aspects of U.S. Export and Import Regulations. This commitment to export and import compliance is demonstrated in GTS’ voluntary membership and certification in the U.S. Customs initiated "Customs–Trade Partnership Against Terrorism" (C-TPAT) program, which promotes industry and government cooperation to implement security measures to enhance cargo security.

As an ISO 9001:2008 certified company, our policies and procedures are designed to integrate precisely with all U.S. Government entities’ regulations including, but not limited to:

  • Bureau of Industry & Security (BIS), U.S. Department of Commerce
  • Transportation Security Administration (TSA), Department of Homeland Security
  • Federal Aviation Administration (FAA)
  • Department of Defense Trade Controls (DDTC), U.S. Department of State
  • Office of Foreign Assets Control (OFAC), U.S. Department of Treasury
  • Occupational Safety & Health Administration (OSHA)
  • Federal Maritime Commission (FMC)

Key Elements for Success

Our Compliance Management Program relies on several crucial elements, including:

  • A clear commitment to compliance control from our upper management,
  • A written procedure that clearly defines our compliance program
  • Constant monitoring and auditing of our Compliance Management Program
  • On-going training programs for all employees
  • On-staff export Compliance Officer
  • Thorough recordkeeping
  • Strict enforcement of our export control procedures
  • Clear and frequent communication of any change in regulations with staff
  • Proper handling and internal reporting of potential export violations
  • Swift implementation of corrective actions

Identifying Risk - A Proactive Approach

Under the direction of GTS’ Compliance Officer, our export process allows for quick identification and screening of all potential risk shipments prior to transport. For each shipment, we verify:

  • The nature of the commodity (Is it controlled/should it be controlled? Is it dual use?),
  • The parties involved (USPPI, Known Shipper or Unknown Shipper, Ultimate Consignee),
  • The final destination of the shipment (Country under sanctions or not?) , and
  • The end-use (What is the commodity going to be used for at final destination?).

Responding to Issues, Resolving Problems

GTS Staff receives regular and extensive training, preparing us to quickly identify potential "Red Flag Indicators". Whenever a potential problem is identified, we have a clear and well-defined escalation process in place so that the transaction can be stopped and the issue resolved. Specific training includes familiarization with:

  • TSA regulations (TSA mandatory security training),
  • FAA regulations (Dangerous Goods training),
  • BIS regulations including Commerce Control List, Export Control Classification Number and categories, basic compliance questions (What, Where, Who and For What Purpose), country charts, crosscheck restriction lists (including Denied Persons Lists, Unverified List, Entity List, Special Designated Nationals list, Debarred List, General Orders and all lists involved under the Nonproliferation Sanctions), proper AES filling (EEI), license lodging and monitoring,
  • C-TPAT regulations and requirements, and
  • ITAR regulations.

Compliance - Everyone’s Concern, Everyone’s Responsibility

At GTS, compliance is an organizational priority from senior leadership to warehouse staff. Each member of our team accepts it as a primary concern and responsibility. We are a key part of the supply chain, and as a vendor our goal is to make sure that we protect all our clients from potential violations.

Online References

Bureau of Industry and Security http://www.bis.doc.gov

Census Bureau http://www.census.gov/foreign-trade/aes/index.html

Directorate of Defense Trade Controls http://www.pmddtc.state.gov/compliance/index.html

Transportation Security Agency http://www.tsa.gov/what_we_do/layers/aircargo/index.shtm

Office of Foreign Asset Controls http://www.treas.gov/offices/enforcement/ofac

Transportation Security Agency http://www.tsa.gov/what_we_do/layers/aircargo/index.shtm