A few years ago I facilitated a short but very rewarding eight hour seminar on the International Traffic In Arms Regulation (ITAR) Overview. I am grateful to the staff at the University of Alabama in Huntsville and the North Alabama Trade Association for both sponsoring the event and allowing me to present. I found the course rewarding as I presented to a mixed audience of 30 professionals ranging from shipping and receiving specialists to executive vice presidents. The mix also consisted of professionals with various degrees of know-how as consultants, attorneys, technology control officers and those brand new to the field shared experiences and learned from one another. As a compliance officer in various disciplines, I have had the privilege of leading security and compliance teams and seminars on multiple topics
Though this was my first of hopefully many export regulations seminars, I noticed the similar need in the compliance field. Regardless of the discipline, compliance works best when driven from the top down. No matter the program a compliance officer intends to build or support, Influence is key when developing it whether security, privacy protection, safety, export, etc. Experience and technical savvy are great to have however, minus influence; the person is just an administrator playing catch-up in a crucial game.
Let’s test your knowledge of international operations. The following situation is pure fiction, but is based on issues facing businesses everyday. This situation is tricky enough with unclassified contracts, but the addition of possible classified work may complicate the issue. Try to answer the following question:
As the security manager of a classified facility, you have many responsibilities including approving classified visits. Not a problems since most visit requests are handled through agency approved data bases . Besides, you have a very large staff and the process is pretty much routine until….
A program manager enters your office and informs you that her foreign customer wants to send an employee to work onsite on a classified program for six months. The program manager wants you to give her a visit request form that the foreign company can use to submit a visit request. You think about this for a moment and realize that though the situation is unusual, it should be a workable solution. Do you provide the visit request form? Why or why not?
Readers of this newsletter can use the same questions while conducting walk around security or otherwise conducting a security survey. Field these questions to your teams. If they respond correctly give loud and public praise. If they answer incorrectly you have just created a training opportunity. Proceed with diplomacy. Use the data you collect as a foundation to designSecurity Defense Lawyer