BIS update self-audit questionaire sheet

On Feb 19, BIS updated their self-audit questionnaire sheet, which is useful tool to determine whether a company's ICP is adequate enough to minimize the risk for violation of US export control. The URL is below.

http://www.bis.doc.gov/complianceandenforcement/emcp_audit.pdf

The material is 30 pages check list by fulfilling yes or no, and comment if necessary.

As the export operation is different by company, and each company have unique activity.
The list is just an example and the auditor is encouraged to make use of it and modify if necessary, to best accommodate the practice of each company.

Not only audit purpose, but according to US Commerce Dept., "may be used to create a new program or to assess whether internal controls have been implemented."

I looked through the entire pages, and my impression is the number of questions are too many, a bit redundant. In actual audit operation, an auditor had better narrowly focus the questions by eliminating some questions. In most cases, an auditor visit many divisions or departments and pose same questions to many different people. Practically, by preparing pre-audit questions, an auditor is suggested to narrow down the focus points.