“Within nine months, Lambda has to complete an audit of their Export Controls Compliance Program utilizing the exact BIS sample audit module... they have to prove IP blocking, geofencing, and verification of access information.”
Trade Compliance Brief - Export Control and Sanctions Insights · BIS Enforcement Analysis Lambda Research Corp Case: EAR99 Software Updates, Access Information, and Entity List Risks
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What was described
must complete a comprehensive internal audit using the BIS sample audit module within nine months
Said nearby on the same subject
“Within three months, Lambda must designate at least two employees to complete mandatory export compliance training and submit the certificates of attendance to the BIS Boston Field Office.”
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Said on Trade Compliance Brief - Export Control and Sanctions Insights
“The way that I like to think about them in regards to internal audits is five independent layers that if all of them exist, it's a system designed well enough to be used in audit settings”