I visit lots of companies and see many more people at training courses
and I’m worried about the trend I’m seeing – companies and their staff don’t
know why they are doing things and they’ve forgotten (if they ever knew) the
basics.
Take the control and procedures for using Export Licences. Often there is no procedure, so what they
should be doing is in someone’s brain and if they leave (or are made redundant)
the people taking over can only follow previous examples. And then they forget to do something, eg
notify HMRC in Southampton of the use of an individual licence for goods going
into the EU, mild panic – the other person had always done that … but nothing happens. No one chases them, no letter from HMRC about
breaking the law … well, then, let’s not bother – it’s time consuming and
delays shipment to do it and if no-one seems worried I’ve got plenty more
things to get on with. But it’s a legal
requirement – the staff just hasn’t been trained and fail to understand how
important it all is.
I was asked to assist one company recently to create a Corrective Action
Plan - they are under HMRC investigation over numerous offences against the
Export Control Act – the offences include exporting licensable goods without a
valid licence; not checking end-user details (diversion via EU to controlled
destinations occurred); not being able to identify controlled goods/technology
internally; military technology being hand-carried overseas on laptops,
etc. The offences date back 4 years …
coincidently it was just over 4 years ago that they had made their logistics
manager redundant. He was a nuisance
anyway – always asking lots of questions, stopping exports, expecting them to
turn down orders, slowing things down.
Everything worked so much better without him … until, of course, HMRC
caught up with them. By not
acknowledging the importance of export licensing controls and intentionally
ignoring previous procedures the company is in a very difficult position
(potentially 10 years imprisonment looms over the Chief Exec). First step – their right to export was
removed; 3 months later we have re-established export control compliance and
they are exporting again but the fines and criminal penalties still hang over
the business. I wonder what happened to
that nuisance of a logistics manager.
They’d have him back in a shot, now!
How can Strong and Herd LLP help?
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