You are an executive at a major firearms manufacturer. You operate in an intensively regulated industry, where you are expected to physically ID your products down to the component level. There are rules and regulations surrounding how long it takes you to mark, acquire, dispose, and record the history of each item. The rules change often, and are sometimes fuzzy in detail. Misinterpretation can lead to regulatory violations, increased third party oversight and in some cases – loss of license. A lot is at stake, and it does not take hyperbole to make it serious.
Long-term industry employees are seeing Federal and State driven proposals that threaten product design, distribution, and end user ownership. Regulatory inspections appear to be improving, at least from an auditor’s perspective. And, the ATF’s lens is changing from an agency that was once administered by the IRS to one that now resides under the power of the Department of Justice.
Our team has redefined the standards for ATF compliance excellence at global industry giants.
"The" leading guide for operationalizing compliance with ATF Firearms Regulations and Gun Control Act. This book is a must to have for all Compliance, Legal and Operational personnel working in the firearms industry. It is a practical guide to assist organizations with ATF compliance - operationalizing rules and regulations in an effort to increase general controls, firearm marking controls, firearm tracing controls and physical firearm control throughout manufacturing, distribution and retail environments.(Purchase on Amazon.com)
The Obama Administration continues the objective of reforming U.S. export controls. This reform effort is a comprehensive overhaul of the regulations controlling U.S. exports, and to date has included substantial revisions to the list of items controlled by the Departments of State and Commerce.
Our team has provided Import / Export training and have implemented Import / Export compliance processes and programs for global organizations.
The ITAR can be found in Title 22 of the Code of Federal Regulations, Chapter I (one), Subchapter M. The ITAR consist of 11 parts (Parts 120-130 of Subchapter M) implementing the AECA in controlling the manufacture, export and temporary import of certain controlled articles and technology from being transferred to objectionable persons, entities and countries.
Our team has provided ITAR training and have implemented ITAR compliance processes and programs for global organizations.
In 2010, Mr. Lanny Breuer, the Assistant Attorney General, Criminal Division of the United States Department of Justice made some very strong statements about his FCPA violations. Using language that lacked even a hint of normal “government-speak,” Mr. Breuer made it very clear that any individual caught violating the Foreign Corrupt Practices Act (FCPA) would be held accountable for his or her actions and that his department’s enforcement of the FCPA would include the full force of the U.S. government.
Our team remediated the industries largest and most prominent FCPA investigation under the eyes of the US DOJ and SEC.
If you “believe” your organization is compliant because: (1) you provided training; (2) you have an “honest” culture; or (3) because a Federal investigator hasn’t told you otherwise, you may be putting the corporate enterprise at increased risk. There is a big difference between being “compliant” and having a “Compliance Program.”
This book provides practical lessons pertaining to the FCPA, U.K. Bribery Act and broader Anti-Corruption / Anti-Bribery standards for Board Members, Chief Executive Officers, General Counsel and other corporate executives who seek to lower their enterprise risk profile by learning simple strategies from tested compliance veterans. (Purchase Kindle Version or Purchase the printed version on Amazon.com).
The justifiable burden Sarbanes-Oxley has led to enhanced financial reporting, but many companies have failed to adopt an internal process that places management with ownership of the process, visa vie a 3rd party.
SOX reporting remains in most companies an over burdened exercise that does not take advantage of the available efficiencies and operational benefits. Improving Sarbanes-Oxley compliance through increased efficiency can help a company reduce costs, increase compliance, and leverage operational benefits.
Our team has achieved SOX compliance too many times to count. This includes the assessment and optimization of existing programs to development from scratch. Our engagements included everything from: Training on the regulation; Roles and Responsibility Design; Identification and Reduction of Key Controls; Integrating Sarbanes-Oxley with Operational Controls; Automating Controls and Spreadsheets; Test Methodologies and Execution; and Board / Audit Committee Reporting.