Managing Disclosures

TRD-319

Course Description:

This advanced six-week online course examines the topics of voluntary and involuntary disclosures. Any organization, large or small, bound by the U.S. Government’s International Traffic in Arms Regulations or Export Administration Regulations or other regulations may find the concepts and topics reviewed in this course helpful in determining its own disciplined and unique methods for making voluntary disclosures and to being prepared for investigations and directed disclosures. As a final project, students design a position paper using the concepts from this course.

Prerequisites:

  • Understanding the ITAR (TRD-306)
  • Understanding the EAR (TRD-307)
  • Export Compliance Documentation (TRD-311)
  • Ethics in Trade Compliance (TRD-320)

Course Credit: 3 Credit Hours

Major Course Topics & Course Outcomes

As a result of the group and individual activities included in this course, the student will acquire the following knowledge and skills that can be applied to the workplace:

Disclosure Regulations

  • Recognize the reasons for Voluntary Disclosures.
  • Identify the various government regulations that impact disclosures
  • Recognize the organizational groups associated with disclosures.

 Appropriateness of Disclosures

  • Assess the appropriateness of making disclosures: Pros and Cons
  • Determine the requisite steps prior to making a disclosure.   
  • Integrate risk management principles into the disclosure decision-making and process.

Scope of Disclosure

  • Determine the time frame as an element of the voluntary disclosure.
  • Determine the scope of events to be made in the disclosure.
  • Explain the importance of documentation on disclosure.

Organizing the Process of Disclosure

  • Assess the use of templates and the importance of non-templated (unique) data.
  • Appraise possible multiple violations for one event.

Mitigation and Payment

  • Assess the advantage of ISA on CBP Voluntary Disclosures.
  • Provide examples of mitigating, aggravating, and neutral factors.
  • Assess payment parameters and alternatives.

Investigations

  • Assess the impact of an investigation on the exporting/importing organization.
  • Articulate the Constitutional and legal parameters for an investigation.

Directed Disclosures

  • Recognize the legal requirements associated with directed disclosures.

Followup of Voluntary Disclosures

  • Identify the steps in follow-up of a voluntary disclosure once made.

 

 

For current Course Materials click the provided link. Look for the Course Name & Code, to view the course materials needed for class.
 
 

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