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CASE STUDY: This high-end Fashion Retailer boosts export control compliance in cryptography

Client name:

Global High-End Fashion Retailer

Nature of instruction and challenge involved

With the use of cryptography (encryption) becoming more widespread across many products and industries, including the retail sector, governments around the world have begun to take notice and started extending export controls in the area of ‘information security. Export control laws have been written up with the hope of only “catching” items for control that are deemed harmful if in the wrong hands. The attempt to exclude many civil and commercial items, however, resulted in a complex set of controls and confusion as to what is and is not controlled.

This global high-end fashion retailer was aware that some of their sophisticated equipment uses cryptography. The challenge was to identify if the items concerned were covered by the applicable controlled dual-use lists.

Finally, extensive awareness-raising training on export controls has to be delivered to a sector of the economy, not typically associated with export controls.

A great, exciting challenge!

How Customs Manager Ltd. tackled the challenge

First, we explained the Control List in plain English on a step by step basis, (as much as possible) so that the company could better understand when an item is controlled. But would they know which items are delisted and do not require control? So we wrote a report, in which we analysed the important cryptography list and provides examples of items typically excluded from controls.

We took the example of category 5A002 and discussed many examples of the type of encryption items that typically are and are not subject to the UK export control law, with straightforward explanations.

Finally, we discussed what general licences are available to UK exporters, before and after 2021. We looked at the rules of export licencing with the EU after the “economic” Brexit occurred.

This was followed by two detailed training sessions, on EU and US export controls with a heavy focus on category 5 controls, without negating end-use, end-user and destination controls, too.

What evidence do you have that shows that Customs Manager Ltd went 'the extra mile' for this client?

At Customs Manager Ltd, we are passionate about helping companies improve their export control compliance through best-in-class processes and procedures in line with laws and regulations. At the same time, we are commercially minded and know that without a profitable, well run business, there is no export and no economic growth.

Compliance and common sense trade facilitation must go hand in hand, so we look very hard at any opportunity that may come our way to be compliant but only pay what's legally due.

Here, we are proud of the detailed note we created for the client. Not only did it include an executive summary and recommendations for the seedy ready, but for those that wanted to deep dive, it had plenty of examples and a popular annexe with a glossary of terms.

The training was delivered in bite-sized chunks over two days to facilitate learning and not overstretch the brain. We turned it into a workshop rather than a "death-by-powerpoint" training. We covered every question in detail and went through practical examples. We would not end the training until we made sure that every question was thoroughly answered.

Find out more about our LIVE! trainings.

Find out about our On-Demand US Export Control Training

Finally, the learners were treated with free access to the Customs Manager's expert blog on export controls and sanctions, dedicated spaces where new developments would be mentioned and where further explanations could be given, accessible when suitable to the learners. This allowed them to go further and keep on learning even after the actual training had finished.

Finally, the retailer greatly appreciated the access to the VIP helpline for a period of six months, provided free of charge, to cover any further questions they have had.

They are, of course, also invited to regular export control briefings and updates that we provide. Overall, they can leverage a wholistic one-stop-shop service for all their export control needs, now that they are with Customs Manager Ltd.

How did involving Customs Manager Ltd resulted in indirect benefits to the client?

By providing a detailed report on the export control rules in the UK, coupled with through, easy-to-understand explanations and many examples, decision-makers in the company were able to grasp which of their products are potentially subject to export controls. This allowed the company to mark these products and design a process and procedures to manage these additional licencing requirements, improving overall export control compliance.

At the same time, the awareness of export control obligations grew inside the company, allowing more people to consider the impact of such exports. This fashion retailer is now well aware of its export control touchpoints and can take appropriate action.

About Customs Manager Ltd.

Working with us means having a Customs Advisor, Global Trade Expert and Export Controls Consultant, on speed-dial. If you are looking for a customs consultant UK and EU, let us help you trade effectively, efficiently and, of course, compliantly, wherever you want to go in the world.

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