Not too long ago when I posted on Cabela’s settlement of export violation charges alleged by the Bureau of Industry and Security (“BIS”), I noted that part of the settlement agreement required Cabela’s to complete BIS’s “Export Management Systems Review Module.” I went on to criticize that requirement because the Review Module was last revised in May 2000 and contained a number of out-dated requirements, including a requirement to keep a dead-tree copy of the Internet-accessible Denied Persons List. The review module also included questions about the discontinued Shipper’s Export Declarations without any mention of the Automated Export System which replaced the filing of SEDs.

It seems to me that if BIS wants to tout the EMS audit module as the touchstone of export compliance, it might want to update it a little more often than every decade.

Well, as they say, be careful what you wish for because last Friday BIS updated its site with a brand spanking new audit module which, in addition to remedying the out-of-date portions I complained about, is a pretty thorough top-to-bottom revision of the module. It’s longer too — with 31 pages instead of the 18 pages of the old module. (Granted that the font is larger in the new module, it doesn’t appear to be big enough to account for the additional 13 pages.) You can access the module from the page you are directed to when you click the “Compliance Program Assistance” link in the left column of the BIS home page.

Trying to find the module with a Google search, however, may take you back to the old module which, for some reason, is still on BIS’s site. While I was looking for the new module, a Google search took me to this page which included a link to the old module. It looks like these pages have been “de-linked” from the rest of the site, but nothing can hide from Google. So, if you are looking for the new audit module, be forewarned that the old ones are still on BIS’s site

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Copyright © 2009 Clif Burns. All Rights Reserved.
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