Releases of controlled technology to foreign persons in the U.S. are deemed an export to the person’s country or countries of nationality. A release can be visual, oral, or written, and are your company’s biggest risk when it comes to visitor management. Access restriction is an important component of any company’s export control compliance program. It is also part of your internal audit process, so make certain that there is an efficient and centralized location established for all of this information. Consider where company visitors will go and where controlled information is located. We recommend starting with a floor plan and identifying all locations that parts move throughout your facility. Also consider where prints, drawings and pricing information are located and stored, as they too are considered controlled information.
Define visitors broadly. It is not just colleagues that come for meetings. Be certain to clear delivery drivers, cleaning crews, maintenance technicians, etc. Sometimes they are dual citizens, in which case determine their last country of citizenship. Use your Export Control Intake forms to perform due diligence and clear all types of visitors at least annually. This information should be stored in a centralized location, along with visitor logs.
CCAT has products and services that can help implement an effective, audit-proof visitor management system. Our visitor kiosk is a software application where visitors login directly, have their citizenship validated and are automatically screened against the Consolidated Screening List at every visit. The kiosk dates and time stamps this information to ensure a solid database, and knowing when you need to update citizenship annually. Moreover, our forms package contains a comprehensive Export Control Intake Certification that can be immediately implemented to effectively screen all visitors in advance. These products and tools will help increase confidence that your company is in compliance with the visitor management requirements of an effective export control program.