Compliance Management Program

As a key part of the supply chain, compliance is an organizational priority at Interstate. We dedicate significant resources to maintain an effective Compliance Management Program that monitors and enforces all aspects of the United States’ export and import regulations. We also assist with the importing or exporting of commodities, processes that requires a thorough understanding of all legal requirements in the origin and destination countries. Each member of our team places great importance on this responsibility, because it is our goal is to ensure we protect our customers from potential violations.

We have a voluntary membership and certification in the United States Customs and Border Protection Agency’s "Customs–Trade Partnership Against Terrorism" (C-TPAT) program, which promotes industry and government cooperation to implement cargo security measures.

As an ISO 9001:2008 certified company, our policies and procedures reflect all applicable Federal Government regulations of the following agencies:

• Bureau of Industry and Security, U.S. Department of Commerce
• Transportation Security Administration, Department of Homeland Security
• Federal Aviation Administration
• Department of Defense Trade Controls, U.S. Department of State
• Office of Foreign Assets Control, U.S. Department of Treasury
• Occupational Safety and Health Administration
• Federal Maritime Commission

Our Compliance Management Program has been clearly defined in a written document and relies on several crucial elements to be effective, such as constant monitoring and auditing, thorough record-keeping, strict enforcement of export control procedures, proper handling and internal reporting of potential export violations, and swift implementation of corrective actions.

Under the direction of Interstate’s Compliance Officer, our export process allows for quick identification and screening of all potential risk shipments prior to transport. For each shipment, we verify:

• The nature of the commodity (Is it controlled? Should it be controlled? Is it dual use?)
• The parties involved (U.S. Principal Party in Interest, Known Shipper, Unknown Shipper, Ultimate Consignee)
• The final destination of the shipment (Country under sanctions?)
• The end-use (What is the commodity going to be used for at the final destination?)

Interstate’s staff receives regular and extensive training to quickly identify potential "Red Flag Indicators." When a potential problem is identified, we use a clearly defined escalation process to stop a transaction and resolve the issue. Specific training includes familiarization with:

• Transportation Security Agency regulations (mandatory security training)
• Federal Aviation Administration regulations (Dangerous Goods training)
• Bureau of Industry and Security regulations
  • Commerce Control List
  • Export Control Classification Number and categories
  • Basic compliance questions
  • Country charts
  • Crosscheck restriction lists
  • Proper Automated Export System filling (Electronic Export Information)
  • License lodging and monitoring
• Customs-Trade Partnership Against Terrorism regulations and requirements
• International Traffic in Arms Regulations