Incident & Disclosure Management

Proper Disclosure of Non-Compliance

Companies in the defense industry routinely focus on being compliant with International Traffic in Arms Regulations (ITAR) and avoiding fines with the Department of State (DOS). With continuous export control reforms, companies in all industries, including those in defense, are equally concerned with products regulated by the Department of Commerce (DOC). Over a recent six year period, it has been observed that fines levied by DOC exceeded that by DOS by a great measure. Despite properly obtaining export and import authorizations, errors do occur.

The ability to self-disclose identified errors, and demonstrate corrective actions, will help substantially mitigate penalties and fines. OCR’s Incident and Disclosure Management™ enables corporations to implement a uniform and consistent corporate wide policy, and internal review process, to evaluate all incident reports, audit findings, identify corrective actions, and when necessary prepare voluntary disclosures for the government.

Confidential Reporting

Enables any employee to confidentially report incidents or matters of concern related to import or export activities.

Management Reporting

Provides management reporting and tracking of Matters Under Review (MUR) by Empowered Officials, compliance officers, auditors, or legal staff.

Incident Categorization

Assigns regulatory categorization of incidents.

Configure Workflows

Configure compliance workflows to address concerns identified during internal and external audits.

Prepare Voluntary Disclosures

Prepare, file, and track voluntary disclosures to the regulatory government agency.

Management Tracking

Visibility for your compliance and legal executives and avoid any oversight of investigative activity such as weekly, monthly or quarterly summary of incident types with configurable dashboard.

Root Cause Analysis (RCA) of Compliance Incidents

Assign the investigation to the correct personnel in compliance, legal, or functional staff with relevant due dates at various levels of the incident review and identify possible corrective actions that address the core issues causing compliance concerns.

Identification of Regulation or Agency for Incidents

Dual use control under EAR, Military controlled goods under ITAR or EAR, Office of Foreign Assets Control (OFAC) sanction, anti–boycott compliance (BIS 6051-P), Foreign Corrupt Practices Act (FCPA), Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE / ATF).

Secure Communications

Secure access protocols and user authentication to Active Directory using LDAP, SAML 2.0 and Single Sign-On (SSO) tools • Secure web forms support any secure 256 bit encrypted transmission and storage in a Relational DataBase Management System (RDBMS), such as, MS SQL or Oracle.