As with other elements of an ICP, the size of the enterprise, the extent of operations involving strategic items, and the amount of available resources will dictate whether an enterprise decides to conduct training using internal compliance personnel, or opts to rely more on external trainers, consultants, and seminars. Regardless, all trainers should be adequately qualified and experienced – possess an extensive knowledge of your country’s STC laws and regulations, be well-versed in STC compliance functions and processes, and be capable of clearly articulating the specific requirements of your enterprise’s ICP.

For internal training, it is recommended that your enterprise designate someone as the primary individual responsible for conducting training related to strategic trade control and ICP. In most enterprises, this responsibility is initially assigned to a member of the senior compliance staff, such as the Chief Compliance Officer (CCO) or possibly a Trade Compliance Unit or Committee. In an effort to alleviate the burden on this individual(s), some enterprises will choose to implement a “train the trainer” approach, where senior compliance personnel train a sub-set of employees that have STC compliance-specific job responsibilities (e.g. Compliance Managers or department heads). Those employees, in turn, are responsible for training other employees who are less involved or familiar with STC compliance issues.

Some larger enterprises choose to use external specialists to provide STC compliance training. If choosing an external provider, your enterprise should confirm the credentials of the trainers to ensure they possess the requisite STC knowledge, and will be able to incorporate the specific needs and requirements of your enterprise’s ICP into the trainings.

Next, it is recommended that an individual or body be assigned responsibility for administering and overseeing your enterprise’s compliance training program. Your enterprise might consider designating a senior compliance official or creating a Compliance Training Unit/Team to oversee STC compliance training activities within your enterprise.

This individual(s) or body should be charged with the following responsibilities:

• Analyzing the training needs of the enterprise, in order to determine the most appropriate type, style, and format of training, on an ongoing basis.
• Deciding on the target groups of employees to receive training and customizing the content of the training for each group.
• Developing a training schedule for employees.
• Certifying that necessary or scheduled trainings are completed.
• Maintaining records of all training activities.
• Developing and updating training materials in collaboration with functional compliance personnel, technical personnel (e.g. product classification engineers), and legal counsel.
• Identifying ways to make use of cross-functional training opportunities in related areas such as ethics, security, audits, and operations.

Note: The individual(s) or body tasked with overseeing your enterprise’s STC compliance training activities should consider contacting your national authorities to see whether they provide STC compliance training opportunities for industry. Many national governments conduct STC training seminars for their national industry (usually free or affordable) which can be used to supplement an enterprise’s in-house compliance training program.

It might also be worthwhile to examine relevant government agency websites to determine whether there is information or instructional materials available that could be used as part of your enterprise’s training efforts.

The individual(s) assigned responsibility for oversight of the enterprise’s overall STC training program should develop a schedule for training all employees of the enterprise that have direct or adjunct STC compliance-related functions (sales, contracts, customer service, credit, order processing, shipping, etc.). The frequency of the training depends largely on the size and activities of your enterprise. Other factors that might also affect the frequency of your enterprise’s training activities include: the rate of personnel turnover, the introduction of new strategic products or services, or changes to the STC laws, regulations, and policies in your country. No matter, STC compliance training should be an ongoing and continuous effort, and at a minimum, employees should receive compliance training on an annual basis.

Once the overall schedule for training has been determined, the person or body responsible for oversight of your enterprise’s overall STC compliance training program should decide on the target groups of employees to receive training and customize the content of the training for each group.

Training should be provided to employees at all levels of the organization, but especially new employees, persons in sales, and those in export-related units. In addition, compliance training can benefit employees involved in marketing, research and design, development, engineering, order processing, purchasing, supply chain management, Information Technology (IT), and maintenance and after-sales service. Training is also be especially useful to personnel that conduct intangible transfers of technology (ITT) and those involved in arranging the movement of goods to third countries.

Different training objectives and formats are required for different types of employees and each training activity should be customized to the needs of the attendees. This requires your enterprise to evaluate the training needs of staff throughout the organization and then develop the appropriate training programs.

While STC compliance training sessions should be tailored to meet the specific needs of different audiences within your enterprise, all trainings should address your enterprise’s specific compliance processes, policies, and procedures and identify the areas where there is the greatest risk of non-compliance.

Your enterprise’s STC compliance training may be divided into the following five categories (with possibility of additional sub-groups that you determine require more specialized, compliance training):

1. Introductory Training for New Employees

   It is recommended that all new employees undergo mandatory STC and ICP awareness-raising training upon hire. Topics to be addressed in an introductory training for new employees may include:

   • Introduction to strategic trade control;
   • Overview of the enterprise ICP;
   • The role of empowered compliance officials within the organization;
   • Strategic trade control legal-regulatory requirements;
   • The enterprise-specific concerns underlying STC compliance;
   • The potential for the enterprise’s products to be used for unauthorized end-uses;
   • Your enterprise’s internal control procedures and risk indicators (e.g. red-flags);
   • The employee’s specific duties and the importance of each employee in the overall effectiveness of the ICP;
   • The costs of non-compliance and the consequences for both the enterprise and the individual, if an STC violation occurs; and
   • Reporting, documentation, and recordkeeping requirements.

   
   Note: The ICP Guide may be used to train new employees and the “Implementation Resources” section of the ICP Guide in particular, can be utilized as an educational resource to supplement your training efforts and enhance employee understanding of STC and ICP-related concepts and issues.
    

2. Senior Management/Executive Training

   STC compliance training should be provided to senior management to ensure they are fully aware and invested in their STC compliance role and responsibilities. Training should include enterprise-specific issues (products, services, customers, and diversion risks), provide an overview of the enterprise’s ICP policies and procedures, and explain the potential costs of non-compliance. Training should also discuss strategies for communicating management commitment to STC, allocating the appropriate resources (time, human, and financial) to trade compliance functions, and ways to cultivate a broader culture of compliance within the enterprise.
    

3. Intermediate Training

   Your enterprise should also conduct intermediate-level training for those employees with STC compliance-related job functions or those who regularly deal with STC compliance-related issues (potentially includes program managers /department heads and employees with commodity classification or transaction screening responsibilities). These trainings might address some or all of the following topics:

   • Overview of the purpose and scope of STC;
   • Applicable STC laws and regulations;
   • Enterprise-specific written operational procedures for STC management and compliance;
   • STC licensing process, including license requirements, conditions, and exceptions;
   • Enterprise-specific product and customer diversion risks – includes the potential end-uses/users of the enterprise’s products, the way products can be misused, and spotting and detecting order irregularities and suspicious order inquiries;
   • STC compliance checks and safeguards to be conducted prior to entering into contractual relationships;
   • Commodity classification process and procedures;
   • The roles and responsibilities of all STC compliance personnel;
   • Expectations and objectives regarding ICP audits;
   • The costs of non-compliance and the consequences for both the enterprise and the individual, if an STC violation occurs;
   • Employee reporting obligations and requirements;
   • Recordkeeping and documentation requirements; and
   • Technology transfer issues and restrictions (if applicable).
      
4. Advanced Training for STC Compliance Personnel

   For those employees who are directly responsible for ensuring the enterprise’s STC compliance, it is recommended that they be required to attend advanced formal training on at least an annual basis (ideally, biennially). Trainings may be in the form of on-line classes, internal seminars, or external seminars/ conferences. Advanced training should be intended to keep empowered compliance officials current on legal-regulatory requirements, industry best practices, and emerging STC compliance issues, risks, and trends.

   Those persons responsible for conducting and/or overseeing your enterprise’s training activities should strive to stay abreast of STC compliance best practices by accessing newsletters, trade publications, webinars, and other available sources for strategic trade control and trade compliance information.

   Note: Please reference the “Implementation Resources,” “International STC Resources” sub-section of the ICP Guide for links to many of these publications and resources.
    

5. Refresher Training

   Your enterprise should periodically provide refresher trainings to existing employees. Refresher trainings for employees can address topics such as:

   • Emerging proliferation trends, threats, risks and vulnerabilities;
   • STC regulatory changes and new compliance requirements;
   • Different license types and requirements;
   • Destination, end-use, and end-user screening;
   • Screening of non-listed items – understanding “catch-all” controls;
   • Changes to control lists and enterprise products subject to restriction;
   • New customer review procedures and due diligence measures;
   • Screening trade facilitators and intermediaries (e.g. shippers, carriers, freight forwarders and brokers);
   • How to report and notify, if an act of non-compliance is discovered or suspected;
   • Review of non-compliance scenarios and “real world” exercises to incorporate practical elements into the training.

   
   Note: It is recommended that your enterprise administer a test or quiz at the conclusion of each training activity (irrespective of the audience) in order to assess subject matter comprehension and retention. Some enterprises provide positive incentives to trainees in the form of awards, prizes, and other forms of recognition during and after training and will often publicize which employees, units, or departments scored highest on the trade compliance test or quiz.

Once it has been determined who requires training, in what topics, and at what time intervals; your enterprise must determine the format or style that will be used to disseminate information and train employees. Training varies in the forms it can assume, but there are essentially two styles of training that may be used to satisfy this element of your enterprise’s ICP:

1. Formal training sessions; and

   The formal style of training occurs in a structured setting where meetings or seminars are held “in-person” and agendas are usually followed. Presentations, modules, and exercises may be developed which are applicable to your enterprise and employees. Formal trainings can be held for large or small audiences, and may focus on general or specific topics related to STC and your enterprise’s ICP. Formal training may be centralized by sending all employees to one central location (e.g. Headquarters), or localized by conducting the training at individual sites (if applicable).

   Note: Because of the procedural nature of an ICP, it can be helpful to provide trainees with job aids and other tangible takeaways that provide them with STC compliance-related guidance and tools to use when they return to their jobs. The “Implementation Resources” section of the ICP Guide contains a number of valuable job aids that your enterprise can provide to employees at formal training sessions.
    

2. Informal training methods or ad hoc information exchanges.

   In addition to formal training sessions, informal training methods, such as verbal exchanges and the distribution of strategic trade control resources and information should be implemented throughout your enterprise. Informal training occurs on a periodic and less structured basis.

   The verbal exchange of information is an important means of supplementing your formal training program. You enterprise’s empowered compliance officials and others knowledgeable on strategic trade control or trade compliance issues should be available to employees to answer questions and provide guidance when necessary or appropriate.

   Employees can also benefit from the provision of STC compliance information and resources. Your enterprise should consider the use of written memoranda, handbooks, newsletters, intranet, internet, video, or e-mail as a means to provide continual advisement to employees about the enterprise’s STC compliance policies and procedures.

   The provision of desk training and online tutorials using electronic media, such as the internet and CD/DVDs, can also be used to supplement and reinforce formal training sessions. Your enterprise may also consider developing compliance DVDs that highlight news of good and bad trade compliance practices, or provide a brief training segment on a particular STC compliance issue(s).

   Some enterprises choose to publish and distribute “Internal Compliance Program Handbooks” to employees in an effort to provide additional support and guidance, address frequently asked questions, and clarify the procedural aspects of the enterprise ICP.

   The circulation of written memoranda, which require employees to initial that they have read and understood the information contained therein, can also be an effective way to transmit pertinent STC compliance information to employees.

   Finally, the introduction of a monthly Compliance Update Newsletter or a Compliance Awareness Day/Week can be an appropriate forum to educate employees about new products, STC regulations, proliferation threats and diversion risks, and your enterprise’s compliance practices or procedures.

   Note: The “Implementation Resources” and “ICP Implementation Aids” sections contain a compliance newsletter template and numerous STC training–related resources/aids that might benefit your enterprise’s training efforts.

Both training styles may be combined within your STC training program to achieve maximum effectiveness. Here again, the style and format of training used is contingent on the overall size, budget, and unique circumstances of your enterprise.

The individual(s) or body responsible for overseeing STC compliance training should keep a record of all STC-related training activities. Archiving records of training enables your enterprise to track and verify which employees have received training. Training records also provide evidence that the enterprise’s STC compliance expectations have been communicated and that employees have been advised on their role and obligations in supporting compliance efforts within the organization.

Your enterprise should consider developing procedures to identify the types of training records and information that should be retained. It is recommended that a training log for each training event be maintained and that records include the date and location of the training, the instructor(s) name, the topics discussed, the format of training utilized, and the identity of all employees in attendance. The contributions, insights, and suggestions made by employees during training activities should be documented by empowered compliance officials and may be used to augment future training and awareness-raising efforts. Employees should also be encouraged to complete a feedback form at the conclusion of each training activity in order to gauge the impact and effectiveness of the training.

Enterprises should also retain and preserve any documentation or records of employee participation in external events, conferences, and seminars; and/or the completion of any online courses. Each employee’s personnel file should include a record of all STC compliance-related training received. It is recommended that training records be maintained in accordance with your enterprise’s established recordkeeping procedures, but at a minimum, training records should be preserved for a period of no less than five years.

It is essential that all training materials are kept relevant and up-to-date. As STC legislation and policies evolve, it is appropriate for employee training to be updated accordingly. Updates to training materials should be conducted by qualified compliance personnel within your enterprise. The individuals responsible for conducting and/or overseeing STC compliance training activities should collaborate with other functional compliance, technical, and legal personnel to review, develop, and update your enterprise’s compliance training materials.

At a minimum, compliance training materials should be reviewed and if necessary, updated, on an annual basis. Furthermore, when there are changes to relevant STC laws or regulations, national control lists, or internal policies or procedures, it is incumbent upon your enterprise to promptly review and update training materials correspondingly.