Export Compliance Checklist Template

Owned by the export compliance lead. Enter the planned export date, the day the goods leave: every due date counts from it in working days, and this template allows four working weeks before it. Say whether the goods leave the United States or the United Kingdom; each task then shows that country’s rules.

• Record the shipment, the export date and the people — the order or shipment reference and the goods, the customer and the destination country, where the goods leave from, the planned export date, and the five people this checklist assigns
• Collect the order details and every party to the transaction — the goods, quantities and value from the order, the Incoterms® rule, and every party: the buyer, any intermediate consignee, the ultimate consignee, the end user and the freight forwarder, with addresses
• Check whether this customer and item have been exported before — earlier shipments of the same item to the same customer, the classification and licence used then, and anything that has changed since: the item, the end user, the destination or the rules
• Confirm the route, the transport and who makes the export filing — how the goods travel, any country they pass through or are transhipped in, the freight forwarder or customs agent, and who makes the export filing

Classification is what the item is for export control purposes: its place on the control list, or not listed. The engineer gives the technical data, and the export compliance lead classifies the item from it. The commodity code for the customs declaration is a separate number found in the same phase.

• Gather the technical data for the item — the datasheet and specification, what the item does and its performance figures, any software or technology that goes with it, and any classification the manufacturer or supplier gives
• Check whether the item is military, dual-use or neither — whether the item is specially designed or modified for military use, can have both civil and military uses, or is an ordinary commercial item, recorded before the classification
• Classify the item against the control list — the control list entry that describes the item, or a record that it is not listed, with the reasons for control and how the answer was reached
• Ask the authority for a classification if the answer is unclear — where the item could fall under more than one entry or none, a formal classification request to the export control authority, or a record that it was not needed
• Check the item for US-origin parts, software or technology — whether a UK-made item contains US-origin parts, software or technology, and if so whether US re-export rules apply to it
• Find the commodity code for the export declaration — the customs commodity code for the goods, which is a separate number from the control list classification

Every party in Phase 1’s table is checked against the restricted-party lists, and the owners of the customer and the end user too. A possible match is reviewed before anything else happens. Lists change daily, so Phase 8 screens the parties again just before the release.

• Screen every party against the restricted-party lists — each name and address from the parties table searched on the lists that apply, with the date, the lists searched and the result for each party
• Review each possible match and record the outcome — each possible match compared with the listing: full name, address, country, dates and identifiers, and recorded as a false positive or escalated as a match
• Stop the transaction and escalate the confirmed match — no shipment, delivery or payment while the match is open, the release approver and your legal adviser told, and any report the law requires made
• Check who owns and controls the customer and the end user — the owners of the customer and the end user, so far as you can find them, checked against the same lists, because some restrictions reach companies a listed party owns

The destination country, and any country the goods pass through, are checked for embargoes and sanctions that reach these goods. A sanctions concern adds a task to find out whether the export is banned or needs a sanctions licence.

• Check the destination for embargoes and sanctions — the destination country checked for arms embargoes, trade sanctions and other restrictions that apply to these goods or this customer
• Check whether the sanctions prohibit the export or need a sanctions licence — the sanctions measures read for these goods and parties, and a conclusion: prohibited, allowed under an exception, or allowed only with a sanctions licence
• Check the route for transit and diversion risk — the route from Phase 1 checked for transit or transhipment countries that change the rules, and for a route that is unusual for these goods and this destination

Who will use the goods and what for. The account manager asks the customer, and the export compliance lead checks the answers against the red flags and the end-use controls, which can require a licence even for an item that is not listed.

• Get the end-use and end-user statement — a statement from the customer or end user of who will use the goods, where and for what, signed where your process or a licence application needs it
• Review the order against the red flags — the order, the customer and the route checked against the red flag list, each one found recorded with the questions asked and the answers
• Check the end-use controls that apply even to unlisted items — whether you know of, or have been told of, a weapons of mass destruction or military end use, or another end use the rules control, recorded with the reasons
• Escalate the red flags that are not explained — the unexplained red flags taken to the release approver, with what was asked and why the answers are not enough, and a decision to stop, ask more or seek advice or a licence

With the classification, the destination, the parties and the end use known, the export compliance lead decides whether the shipment needs a licence, is covered by a general authorisation, or needs none. An individual licence adds the application, and the planned export date may then move.

• Decide whether a licence is needed — the classification checked against the destination, the parties and the end use, and the answer recorded: no licence needed, a general authorisation that covers it, or an individual licence, with the reasons
• Apply for the individual licence — the licence application made with the classification, the parties, the end-use statement and the technical data, and its reference recorded
• Check the conditions of the License Exception or open general licence — the exception or licence read in full, each condition and exclusion checked against this shipment, and the exporter registered to use it where the licence requires
• Record the licence and its conditions — the licence number, its expiry date, the items, quantities and values it covers, and every condition that applies to this shipment

The documents that travel with the goods carry the licence or exception and the statements the rules require, and the forwarder or customs agent gets the data for the export filing. Nothing is filed yet: that waits for the release.

• Check the customer can import the goods — the customer asked whether its country needs an import licence, permit or certificate for these goods, and what documents its customs will want
• Prepare the commercial invoice and packing list — the invoice with the full description, value, parties and Incoterms® rule, and the packing list, both matching the order and the parties screened
• Put the licence reference and control statements on the documents — the licence, exception or open general licence reference and any statement the rules require, on the invoice and the transport document
• Give the forwarder or customs agent the export control data — the classification, the licence code or reference, the commodity code, the parties and the value, in writing, for the export filing

The parties are screened again, the export compliance lead sums up, and the release approver alone decides whether the shipment may leave. Nothing after the decision can be completed until the approver completes it. Not released hides Phase 9 and shows the task to hold the shipment.

• Screen every party again before the release — every party screened again on the lists that apply, because lists change, with any change from Phase 3 recorded
• Prepare the release summary and recommendation — the classification, the screening results, the destination and end-use checks, the licence route and the documents, with a recommendation to the release approver
• Decide whether the shipment may be released — Released, Released with conditions or Not released, with the conditions or the reasons, recorded by the release approver alone
• Hold the shipment and record why — not released only: logistics and the account manager told to hold the goods, the customer told what it can be told, the reasons and the records kept with this checklist
• Meet the release conditions before the hand-over — each condition the release approver set, met and recorded before the goods are handed to the carrier

Applies only when the release approver releases the shipment, with or without conditions. The export filing is made, the goods and their documents go to the carrier, the export is confirmed, and the records are kept for the period the rules set.

• Make the export filing and record its reference — the export filing made by you or your agent before the goods leave, or the exemption that applies, with the reference recorded
• Hand the goods and documents to the carrier — the goods handed over on the export date with the invoice, the packing list, any licence and the filing reference, checked against the release
• Confirm the goods left and keep the proof of export — confirmation that the goods left the country, kept with this checklist as proof of export
• Record what the shipment used of the licence — the quantity and value shipped against an individual licence, or the use of the open general licence or License Exception, for the licence’s own records and reports
• File the export records for the period the rules set — the classification, screening records, end-use statement, licence or exception, documents, filing reference and proof of export, filed together and kept for the period that applies
• Update the records for the next shipment — the item’s classification in your product records, the customer’s screening and end-use file, and anything learned that changes how the next shipment to this customer is checked