Do you know if your customs compliance program is effective?  Do you know if your export controls and economic sanctions internal controls are working properly? Do you have any internal controls to detect payments of bribes to foreign public officials or the recording of such improper payments in your books and records?

If the answer is “No” – What kind of wake up call would you like?  Do you prefer loud alarm bells?  Do you prefer a bucket of ice cold water?  Do you prefer a shock?

If you do nothing, you may experience a wake up call that is not welcomed and unexpected.  The auditors may arrive and find serious mistakes.  A CBSA officer may arrive to conduct a verification only to find unverifiable transactions.  A disgruntled employee may download information from your computer systems and provide a neatly wrapped package to the justice officials, who will arrive with a search warrant.  There are so many scenarios of a wake up call into a nightmare.

There is only one way to prevent the nightmare scenarios and unanticipated wake up calls – that is, to implement strong and verifiable internal controls.  Senior management cannot be sure that the employees know the rules unless there is a policy manual (compliance program) that sets out the rules clearly.  Senior management cannot know that the employees know what the rules require them to do unless there is a training program.  Senior management cannot know that the employees are following the rules without internal checks and balances.  A mini internal audit is a great way to determine if there are gaps in the compliance program.  There needs to be someone who makes compliance a priority.