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Company Profile:
US Information Security MNC

Background:
The company specialises in developing, manufacturing and trading of information security products and operates multiple distribution facilities globally, Singapore being one of them in order to meet with customers’ demands. Although a significant portion of its products universe was subject to strategic trade controls (aka export controls) themselves under the US Export Administration Regulations, the company enjoyed license exemptions for its exports out from the US and hence export control licenses were not applied for then and recorded as such on its internal ERP order management system.

There was however an internal oversight when the ERP system mistakenly applied the license exemptions for all its controlled exports out from the distribution facility in Singapore over an extended time period. Under the Singapore’s Strategic Goods Control Act (SGCA), the US license exemptions do not apply and require strategic goods permits (i.e. export control license) if the product itself is subject to control within the Singapore strategic goods control list.    

In this case, the company unwittingly committed export control violations under the Singapore export control laws and the number of affected export shipments was significant. The company was keen to rectify the situation as soon as possible with Singapore Customs (the governing authority for SGCA).

Support Rendered:

• Assisted the company to quantify the potential historical exposure in terms of number of prior controlled exports without application of the strategic good permits from Singapore Customs.
• Discussed with various stakeholders in the company and its local third party logistic provider to obtain an independent chronological overview of how the issue occurred.
• Developed and implemented practical corrective actions in the form of a localised Internal Compliance Program (ICP) within the company to prevent future occurrence of similar violations.
• Prepared a voluntary disclosure submission package to Singapore Customs.
• Supported in the company’s application of a bulk strategic good permit (i.e. an overarching permit for all its controlled exports out from Singapore) to facilitate significant controlled export shipment volume on a regular basis.

Benefits to company:

• Achieve successful resolution of the voluntary disclosure with mitigation of penalties under the Singapore SCGA.
• Enhance the company’s internal compliance with Singapore export control laws while minimising operational impact on its distribution facility in Singapore.