Why They Happen, How to Avoid Them, and What to Do if They Happen to You
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Consent agreements are a feared, but recurring feature of the export control and enforcement landscape. The recent announcement of the ZTE consent agreement signals that the Trump Administration has not stepped away from this enforcement option and, in fact, is willing to apply it to new issue areas and regulatory regimes in order to further Administration priorities. This webinar will be valuable to compliance executives and leads, empowered officials, export leads, and practitioners interested in knowing more about trade compliance consent agreements and monitorships. Participants will learn what a consent agreement is, when the Government imposes them, how to avoid them, and what to do if your company becomes subject to one. This webinar will cover:
- What is a Consent Agreement?
- Legal Basis
- When Does the Government Impose Consent Agreements?
- ITAR Agreement Management Defects
- Import/Export Authorization Failures
- Failure to Execute on State Department Commitments
- Inadequate Jurisdiction & Classification Determination & Review
- Insufficient Internal Controls over Technical Data Exports
- 126.1 and Sanctions Violations
- Inadequate Compliance Controls
- How Can Your Company Avoid Consent Agreements?
- Credible Compliance Program
- Identify and Pre-empt Catalyst Events
- Credible Execution of Commitments
- What Should You Do if Your Company is the Subject of a Consent Agreement?
- Select the Right SCO
- Collaborate with the Regulator
- Cultural Realignment
- Address the Catalyzing Event
- Define the End State
- Design Your Future and Build a Program
- Get Help When You Need It
- Monitor and Investigate: Flip Rocks and Prioritize Improvements
The webinar will be presented through PowerPoint slides and will include live video and commentary from Randall Cook and Rosanne Giambalvo of Ankura Consulting. Randall Cook is a Senior Managing Director at Ankura Consulting Group. He has more than 18 years of experience conducting complex investigations and audits, leading and advising organizations engaged with critical operational and compliance challenges, and designing and delivering high-performance, persistent, integrated risk mitigation solutions. Rosanne Giambalvo is a Senior Director at Ankura Consulting Group. She has over 20 years of professional experience, including three years in international trade compliance and over 15 years in financial services. Ms. Giambalvo works with her clients to operationalize trade compliance through the development of international trade compliance policies and procedures, system and process enhancements, and training.
Webinar participants are invited to submit questions during the webinar and the final 30 minutes will be allotted to answering attendees’ questions.
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