Import and Export Compliance Expertise

Since its inception in 1986, GTS has worked to establish an effective Compliance Management Program that integrates all aspects of U.S. Export and Import Regulations. GTS’ voluntary membership and certification in the U.S. Customs initiated "Customs–Trade Partnership Against Terrorism" (C-TPAT) program, which promotes industrial and administrative measures to enhance cargo security, demonstrates its fierce commitment to export and import compliance.

• As an ISO 9001:2008 certified company, our policies and procedures comply 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)

• Directorate 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:

• Our upper management’s commitment to compliance control
  

• A written procedure that defines our compliance program

• Constantly monitoring and auditing our Compliance Management Program

• On-going training programs for all employees

• An on-staff export Compliance Officer

• Thorough record keeping

• Strict enforcement of our export control procedures

• Any change in or of regulations communicated to staff

• Proper handling and internal reporting of potential export violations

• Swift implementation of any necessary 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. Prior to 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?)

     The end-use

     (What is the commodity going to be used for at final destination?)

Responding to Issues, Resolving Problems

The 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 well-defined escalation process in place so that the transaction can be stopped until the issue reaches resolve. 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

• ITAR regulations.

Compliance - Everyone’s Concern, Everyone’s Responsibility

At GTS, compliance is an organizational priority for everyone from senior leadership to warehouse staff. Each member of our team accepts it as a primary concern and responsibility. 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