Compliance Guide for Export Control VS Customs AEO Certification
Author: Ning Jing & Rhea.Yang 2022-04-06On April 28, 2021, the Ministry of Commerce issued Announcement [2021] No. 10 of Guiding Opinions of the Ministry of Commerce on Establishing Internal Compliance Mechanism for Export Control by Exporter of Dual-Use Items and Internal Compliance Guide for the Export Control of Dual-use Items (hereinafter referred to as the “Compliance Guide”). On November 1, the General Administration of Customs (GAC) issued Announcement No. [2021] 88, updating the “Customs’ standards for Advanced Certified Enterprises” (hereinafter referred to as “Customs AEO Certification Standards”) as a supporting provision for the new ustoms enterprise credit management measures. It can be said that this is the guidance provided by the two departments for the establishment of compliance mechanisms for enterprises from their respective regulatory perspectives. For enterprises, if they can integrate the requirements of the Compliance Guide and Customs AEO Certification Standards, embed them into the existing management structure and system, it is an efficient method to establish and improve the internal compliance mechanism. Based on this, this note compares and analyzes the Compliance Guide and Customs AEO certification standards, extracts seven elements that need to be paid attention to in internal compliance, and proposes integration suggestions.
Keywords: Export Control, Compliance Guide, Customs AEO Certification Standards, Comparing and Integrating
I. Compliance Guide and Customs AEO Certification Standards Framework What are the elements of Compliance Guide and Customs AEO Certification Standards? Can the essential content of these elements be extracted into a common framework? Once the element requirements of the framework are met, the requirements of the Compliance Guide and Customs AEO Certification Standards are basically met at the same time? (I) The basic elements of the Compliance Guide and the Customs AEO Certification Standards Graphic 1: The nine basic elements of the Internal Compliance for the Export Control of Dual-use Items Graphic 2: Customs AEO Certification Standards The Compliance Guide has nine elements, namely: drafting a policy statement, establishing an organization structure, comprehensive risk assessment, establishing examination procedures, developing emergency measures, providing education and training, improving compliance audit, retention of data files and preparing management manuals. The newly revised Customs AEO Certification Standards continue to adopt the “1+N” model, it includes general standards and specific standards (standards formulated for different types of enterprises and business scope). The certification standards include five categories of elements, respectively: internal control, financial status, law-abiding norms, trade security and additional standards. Graphic 1 and 2 illustrate these basic elements. Intuitively, the Compliance Guide and Customs AEO Certification Standards differ in the combination of elements. However, if we study the specific regulations of each element, we will find that no matter how these elements are classified, it essentially reflects the concern of the competent authority on the compliance management of enterprises. In the regulatory fields, the competent authorities issue official guidelines for enterprises to establish and improve internal compliance mechanism. Its specific requirements have overlaps which makes comparison and integration with the premise. In addition, the supervision stipulated in these two legal documents is aimed at enterprises engaged in international trade, and both focus on the enterprise compliance in the import and export activities. In other words, it is often the situation that the same company is confronted with guidance requests from two departments regarding internal compliance mechanisms. If enterprises can seek common ground while reserving differences through comparison, integrate the specific requirements of Customs and the Ministry of Commerce for enterprise compliance in practice, and optimize the existing management structure and institutional mechanism. This can be regarded as an efficient method to establish and improve an effective internal compliance mechanism. (II) Seven common elements extracted from the two guidance documents Based on the aforementioned idea, this note takes the consignee or consignor of import and export goods as an example. First, the specific standards and general standards are integrated, which is the standards for Customs to certify the compliance of consignees and consignors of import and export goods, and then compared with the Compliance Guide of the Ministry of Commerce. Through comparison, we found that although the expression of classification is different, the Compliance Guide and Customs AEO Certification Standards both focus on seven dimensions. That is establishing organization structure, risk assessment control, security review, audit system, crisis management and emergency measures, providing training and information and data management. These seven dimensions basically cover most of the requirements of the two departments for the compliance mechanism. Therefore, we establish a comparison framework based on these seven elements to compare the specific provisions of the Compliance Guide and Customs AEO Certification Standards. Graphic 3: Seven common elements extracted from the two guidance documents (III) Specific provisions on the seven elements of Compliance Guide and Customs AEO Certification Standards 1. Establishing organization structure Compliance Guide AEO Certification Standards (General+ Specific) Requirements for organization Organization: 1. Establish an export control compliance committee or appoint a chief compliance officer to perform export control compliance management duties. 2. Set up an export control compliance department or only set up an export control compliance position to organize, coordinate and supervise compliance management, and provide compliance support for other departments. 3. Each business unit strictly implements its own export control compliance management system. Internal organizational structure: 1. The division of responsibilities of departments (posts) such as import and export business, finance, trade security, and internal audit is clear. 2. Designate senior management personnel to be responsible for Customs affairs. 2. Risk assessment control Compliance Guide AEO Certification Standards (General+ Specific) system Comprehensive Risk Assessment System Establish a security access control system Assessment scope 1. Assess business items, customers, technology and R&D, internal operations, export control-related information, third-party partners, etc., as well as risk prevention measures. 1. Conduct a pre-examination of whether the import and export goods have safety access requirements and whether they meet the safety access requirements, and ensure that the goods, origin, production enterprises, consignees and consignees meet China’s safety access requirements. 2. Establish and effectively implement a management system for evaluating and inspecting the security of the supply chain of business partners. 3. Comprehensive assessment: When selecting business partners, conduct a comprehensive assessment of business partners according to this certification standards, focusing on assessing compliance with laws and regulations, trade security and supply qualifications with written systems and procedures. 4. Written documents: In contracts, agreements or other written documents, business partners are required to optimize and improve trade security management in accordance with this certification standards. 5 Monitoring and inspection: regularly monitor or inspect the compliance of business partners with trade security requirements with written systems and procedures. 3. Security review Compliance Guide AEO Certification Standards (General+ Specific) Review procedure design 1. Review before signing the contract Conduct a comprehensive assessment of items, end users, end uses, transportation routes, etc. Do due diligence, such as whether the export items are prohibited or restricted export control items, whether the agents and end users are associated with terrorism, whether the agents and end users are included in the Chinese control list, etc. prohibited or restricted transactions list and the UN sanctions list, etc. Pay close attention to matters such as whether the item is on the dual-use export control list or temporarily controlled; whether the use of the item is consistent with the end use; Whether the customer is an end user, and if the customer is an intermediary, best efforts are required to identify the end user. It is necessary to review the risk level of the country and region where the customer/end user is located, whether the country or region is sanctioned by the UN, whether the information provided by the customer is true, whether the delivery date is clear, etc. Ultimately, the reviewers make a “transaction approval”, “cancellation of the transaction” or “transaction suspension” opinion. 2. Signing the contract Set up export control compliance-related terms to constrain transaction parties to comply with export control-related laws and regulations. 3. Applying for a license After signing the contract, if the transaction involves controlled items, or if the enterprise knows that the relevant items may have risks specified in Article 12 of the Export Control Law, it is required to submit relevant materials to the national export control management department and apply for an export license. If the enterprise cannot determine whether it is a controlled item, it can consult the national export control management department. Before the enterprise obtains the corresponding export license in accordance with the law, it cannot export and deliver goods. 4. Contract performance Before delivery, confirm whether the previous review stages are complete, review the situation of the shipper, check whether the license and shipping documents are consistent with the delivered goods, etc. If there is any problem, please check with the relevant department before delivery. In the process of collection and payment, after-sales service, repair, maintenance, etc., once it is found that the end user, end use, installation location, etc. of the export control items may change, immediately report to the national export control management department. When providing after-sales service, repair, and maintenance to overseas equipment, it is necessary to check whether the previous export of the equipment complies with relevant laws and regulations on export control. Whether the relevant parties are included in the list of prohibited or restricted transactions, and whether the services to be provided and the parts to be replaced need to apply for an export license. 1. Document control: establish and implement the import and export document review or correction system. 2. Before the declaration or entrusting the declaration, the special department or personnel will conduct an internal review of the authenticity, accuracy, standardization and completeness of the content in the import and export documents. The content of the review includes price, classification, origin, quantity, product name, specification, overseas consignor and consignee, packaging type, storage location of goods, transportation route, storage conditions, precautions for dismantling and inspection, labels and signs, etc. 3. If an enterprise implements license management or official certificate management for export to China, it shall conduct an internal review of the authenticity, validity, integrity and consistency of the documents according to the actual import and export situation. Such documents include foreign quality certificates, quality assurance certificates, pre-shipment inspection certificates, certificates of origin, health and quarantine documents, official certificates of food exported to China, official certificates of animal and plant quarantine, animal and plant quarantine licenses, and agricultural GMO safety certificates, etc. 4. For enterprises engaged in processing trade and bonded import and export business, there are special departments or staffs on the position to record the account books related to processing trade goods covering import, storage, transfer, sales, processing, use, loss, and export, etc. and other relevant documents for internal review for accuracy and consistency. 4. Audit system Compliance Guide AEO Certification Standards (General+ Specific) Audit Contents 1. Overall audit: conduct a comprehensive assessment of the company’s internal compliance system for export control, including audits of various parts of the overall compliance system, selected export transactions, and compliance of various relevant departments. 2. Special audit: focus on specific departments, such as sales department, production department, etc., or specific export links, such as delivery procedures, record keeping, etc., to conduct special audits. There is no specific rule on audit content Audit process 1. Determine the scope of business departments and personnel to be audited. 2. Prepare audit templates such as interview questions, transaction audit checklists, etc. 3. Collect written materials from various business departments. 4. Interviews with personnel at all levels of the business departments. 5. Carefully study written materials, interviews, and circumstances of business operating to find out violations. 6. Write the audit report. The report needs to reflect the degree of deviation between the actual implementation and the relevant requirements, in-depth analysis of the reasons for the deviation, and put forward rectification suggestions. And compare the differences between the audit results of this year and previous reports and sort out the rectification and implementation of problems according to the time dimension. 1. Establish and implement an internal audit system for import and export activities. 2. Carry out internal audit more than once a year and establish files of written or electronic data. 3. An enterprise that has become an advanced certified enterprise shall conduct annual internal audits on matters that continue to meet the standards of an advanced certified enterprise. Improvement mechanism 1. Feedback the audit results and rectification suggestions to the audited business department. 2. Report audit findings and recommendations to management. 3. Organize the implementation of rectification and keep track of it. 1. Establish and implement an improvement mechanism for problems found in import and export activities and an accountability mechanism for illegal acts. 2. Matters such as rectification or normative improvement required by the Customs shall be organized and implemented by the legal representative (person in charge) or the senior management personnel in charge of Customs affairs. 5. Crisis management and emergency measures Compliance Guide AEO Certification Standards (General+ Specific) Crisis management and emergency measures 1. According to the report/other information, the compliance department will determine whether to initiate an internal investigation of the company (clarify the criteria for initiating an investigation); determine the scope of the investigation; clarify the investigation procedures; draft an investigation report; take remedial measures; inform the whistleblower of the investigation results as appropriate; report to management; cases related to the identification and remediation of violations can be included in the training content of export control compliance; when serious violations exist; report to the national export control management department. 2. Ensure that reporting channels are safe and unrestricted. 3. Implement the reward and punishment system. 4. Take timely remedial measures. Link up and down to form a risk reporting, decision-making and processing mechanism. At the same time, corresponding correction measures are taken, including but not limited to suspending contracts, stopping delivery, recovering goods in transit, and improving internal compliance systems. Specific requirements are scattered in different elements, such as requiring enterprises to establish and implement import and export document review or correction systems; when disasters or emergencies occur that involve Customs business, they should report to the Customs in a timely manner. 6. Providing training Compliance Guide AEO Certification Standards (General+ Specific) Training Requirements Education and Training： 1. Design different training contents according to job responsibilities. General personnel focus on the concept, significance, relevant policies, management methods and other basic contents of export control compliance. Business departments of export control shall increase training on relevant review procedures of internal compliance system of export control, end-users and end-uses, review priorities, operation methods of relevant information systems/screening tools, etc.；The training of export control compliance departments mainly focuses on China’s export control laws and regulations, policy trends, control list, and advanced experience of international export control compliance. 2. Personnel of export control compliance department are encouraged to participate in external seminars and training regularly. Customs Business Training： 1. Set up and implement the internal training system of Customs laws and regulations. 2. The legal representative (responsible person), senior management personnel in charge of Customs affairs, personnel in charge of Customs affairs and senior management personnel in charge of trade security shall attend internal training of Customs laws and regulations at least twice a year, so as to timely understand and master the relevant management regulations. Security Training： 1. Establish and implement internal training mechanism on trade security. 2. Conduct regular education and training on the risks related to the flow of goods in the international trade supply chain for personnel to understand and master the work of the AEO in the process of ensuring the safety of goods. 3. Regularly conduct crisis management training and crisis handling simulation drills for personnel, so that can understand and master the work that should be done in the process of emergency response and abnormal reporting. 7. Information systems and data management Compliance Guide AEO Certification Standards (General+ Specific) Information systems and data management 1. Filing regularly and randomly checking the filing situation. 2. Complete and accurate retention of documents related to export control compliance. 3. Make clear the filing procedures, storage requirements and filing time limit of relevant documents (generally more than five years). 4. Relevant business departments shall cooperate with export control compliance departments to complete regular archiving as required, and keep relevant documents, information and materials completely according to business and division of responsibilities. 5. Choose the most appropriate archiving method (paper file, electronic file, etc.) according to the actual work. 6. The archived documents may be original documents, duplicates or electronic documents, provided that the duplicates and electronic documents are authentic, accurate and clear, and all marks, information and other features of the original documents shall be retained. 7. If the archived documents need to be provided abroad, they shall be provided in accordance with the requirements of Article 32 of the Export Control Law. 1. To establish a real, accurate, complete and effective control of enterprise production and operation, import and export activities, financial data and other information system, in customer management, contract management, financial management, Customs management, logistics management and other aspects of the function can be recorded, traceable, inquiry, analysis, early warning and effective operation. 2. Production and operation data and data related to import and export activities are timely, accurate, complete and standardized input into the system. The system data shall be kept for more than three years after the import and export goods go through Customs formalities. 3. Main links of import and export activities can realize process retrieval and tracking in the system. 4. Establish and implement information security management system. 5. Provide information security related training to personnel. 6. Any violation of the information security management system that causes damage shall be investigated for responsibility. II. Comparison of Compliance Guide and Customs AEO Certification Standards in Seven Elements Graphic 4:Seven common elements of Compliance Guide and Customs AEO certification standards We have summarized the specific provisions of 7 common elements of Compliance Guide and Customs AEO certification standards with a list. This part compares the provisions one by one under the framework of these seven elements for enterprises to understand and apply them. (I) Establishing organization structure Compliance Guide: Enterprises are required to establish compliance management organizational structure supported by the decision maker (compliance committee or chief compliance personnel), led by the export control compliance department (or compliance position), and implemented by each business unit, providing a reference organization and management system. The implementation requires the implementation of leadership responsibility, the establishment of full compliance responsibility system and AB role work system; Emphasize the principle of compliance independence and priority. AEO Certification Standards: Enterprises are required to set up departments and posts in import and export business, finance, trade security and internal audit with clear division of responsibilities, and assign senior managers to take charge of Customs affairs, clarifying their responsibilities in written form. (II) Risk Assessment Control Compliance Guide: Enterprises are required to conduct a comprehensive assessment of their possible export control risks on a regular basis and identify business links prone to violation risks. The assessment includes operating items, customers, technology and research and development, internal operation, third-party partners, risk prevention measures and other aspects. The implementation should pay attention to comprehensive prudence, regular assessment and hierarchical management. AEO Certification Standards: Establish a safety access control system to control risks, pre-check whether import and export goods exist and meet safety access requirements, and ensure that the goods, origin, production enterprises, consignee and consignor meet China’s safety access requirements. Business partners should focus on the assessment of compliance, trade safety and supply qualifications, and written systems and procedures. (III) Security review Compliance Guide: The core lies in full coverage and whole-process review, tracking every transaction flow from the beginning to the end, comprehensively assessing whether items, end-users, end-uses and transportation routes are involved in regulatory risks before, during, after signing contracts and in the process of applying for licenses, so as to prevent violations of end-user and end-use management. Also avoid the risk of export control because customers and third-party partners are included in the control list. AEO Certification Standards: Mainly around the activities related to import and export goods, the submission of import and export documents and other compliance requirements. For example, relevant posts or personnel are required to truthfully declare, and internal review is conducted on whether the declaration elements are true, accurate, standardized and complete; For those engaged in processing trade and bonded import and export business, internal review shall be conducted on the accuracy and consistency of relevant accounting books, statements and other documents. (IV) Audit system Compliance Guide: There are overall audits for the internal compliance system of export control, as well as special audits for specific departments or links. The audit can be carried out either by special personnel within the enterprise or by an external third-party organization. The audit mainly focuses on whether the review process is followed in the process of dual-use items transaction, whether the internal mechanism operates smoothly, whether the investigation of suspicious matters is effective, and whether the compliance affairs need to be improved, etc. AEO Certification Standards: Adopt internal audit system, mainly for import and export activities compliance. Conduct internal audit at least once a year and establish written or electronic files. If it has become advanced enterprise, it is necessary to conduct internal audits of import and export activities and continuous compliance with certification standards. (V) Crisis management and emergency measures Compliance Guide: Enterprises are required to raise their risk awareness, open up channels for internal reporting, set up reasonable internal investigation procedures, take remedial measures in time, and report to the competent authorities on their own initiative when serious illegal acts are discovered. AEO Certification Standards: The requirements of the Customs for crisis management and emergency measures are scattered in different elements, such as requiring enterprises to establish and implement import and export document review or correction system; When disasters or emergencies occur that involve Customs operations, they shall promptly report to the Customs, etc. (VI) Providing training Compliance Guide: Design different training according to the responsibilities of different positions to ensure that the personnel understand their responsibilities in respect of export control compliance. The problem can be used as a training case to prevent the re-occurrence of alert-related situations. Through the participation in export control compliance training, examination into the assessment to promote the training effect. AEO Certification Standards: Legal representative (responsible person), senior administrative personnel in charge of Customs affairs, personnel in charge of Customs affairs and senior administrative personnel in charge of trade security shall attend Customs business training at least twice a year. If the legal representative (responsible person) authorizes the management personnel actually in charge of the daily operation of the enterprise to participate in the training, the authorized scope of the management personnel shall be listed in written form. (VII) Providing training Compliance Guide: It requires enterprises to keep the documents related to export control completely and accurately, and puts forward specific requirements for the storage and filing of documents and data. Requests for contact by telephone, fax, e-mail and other means should also be recorded as appropriate, and relevant documents should be kept for at least five years. AEO Certification Standards: It is required to establish an information system that effectively controls enterprise production and operation, import and export activities, financial data, etc. Production and operation data and data related to import and export activities shall be entered into the system in a timely, accurate, complete and standardized manner. Relevant information and main links of import and export activities can be recorded, traced, inquired, analyzed and warned. The system data shall be kept for at least three years from the date when the import and export goods go through Customs formalities. III. Comments and Integration Suggestions (I) Establishing organization structure Brief comments: Compliance Guide and Customs AEO certification standards require enterprises to set up corresponding organizational structures, clarify job responsibilities and personnel division, and give full play to compliance audit obligations. The compliance Guide emphasizes the principle of compliance independence, requiring compliance departments to be independent from sales, export and other business departments, and compliance management to be free from interference of other departments and personnel. In case of conflict of opinions on compliance matters, the principle of compliance priority shall be adhered to. Customs AEO certification standards require that departments (posts) of import and export business, finance, trade security, internal audit and other departments (posts) have clear division of responsibilities, and should designate senior management personnel to be responsible for Customs affairs. Integration suggestions: The enterprise needs to evaluate the existing organizational structure and post setting, so as to take into account the compliance requirements of the Ministry of Commerce and Customs in terms of organizational structure. For example, in addition to existing Customs affairs, import and export business, finance, trade security, audit and other departments (posts), compliance institutions or posts should be embedded in the organizational sequence to ensure their independence and full authorization, so as to achieve the principle of compliance priority. (II) Risk assessment control Brief comments: Although both of them have risk assessment and prevention requirements for trading parties and third-party partners, it can be seen that they have different concerns on risk assessment systems. The compliance guide focuses on export control risk assessment, such as whether business items fall into the control list, counterparties, and whether a third party into the control list, whether technology and research and development related to export control, etc. AEO certification standards pay more attention to whether the flow of import and export goods, the supply chain and related subjects in the whole trade chain, import and export behaviors meet the institutional requirements of the competent authorities. Integration suggestions: The key is to establish a risk assessment system covering the whole trade chain, identify business links prone to violation risks through comprehensive assessment, and match compliance resources and review content according to risk levels. For example, establish customer risk and red flag screening system, identify high-risk areas, products and positions, and clarify work procedures, standards and emergency mechanisms. If the red line is crossed, the emergency mechanism will be activated immediately. (III) Security review Brief comments: Both of them involve the review of documents, but the focus of the specification is different. Enterprises need to embed relevant requirements into the existing working mechanism or process through the workflow and system setting, so as to prevent compliance risks through the security review procedure. Integration suggestions: The key point is to improve the internal working process and working mechanism, by clarifying the implement internal compliance control before signing, signing, license application and contract performance, for each transaction to do a good job in the whole process of risk review. In addition, establish and implement the internal review system for authenticity, validity, integrity and consistency of all kinds of documents such as certificates of origin, health quarantine documents, and statements of import and export trade books. (IV) Audit system Brief comments: Both the compliance guide and AEO certification standards of Customs take the audit system as a means to “inquire” whether the existing system and mechanism of enterprises are reasonable, so as to discover compliance risks in time and correct mistakes through improving the mechanism. However, the audit content and scope of the two are different. Integration suggestions: The audit system shall cover responsible departments, implementation frequency, workflow, work content, how to cooperate between departments, how to improve problems found and how to evaluate after improvement, etc. It shall be noted that requirements of compliance guide and Customs AEO Certification standards shall be taken into account at the same time. For example, in the comprehensive audit, the audit of import and export activities is naturally covered, and the establishment of written or electronic files. (V) Crisis management and emergency response Brief comments: Crisis management and emergency measures focus on internal investigation procedures once compliance risks are identified, the division of labor between departments, and when to report to the competent authorities to stop losses in a timely manner. Its core is self-examination and correction, is the enterprise for their own “illness” under a “good medicine”, to avoid loss expansion. Integration suggestions: This element involves activating an emergency plan, and how to remedy when they are found to be true, and how to minimize losses to the enterprise. Enterprises can establish reporting and internal emergency mechanism to encourage personnel to report suspected violations in accordance with internal compliance mechanism. Upon discovering compliance risks, the enterprise shall promptly take remedial measures such as suspending contracts, stopping shipments, recovering goods in transit, and improving internal compliance systems. In case of serious illegal acts, report to relevant state departments in time. (VI) Providing training Brief comments: Both of them emphasize training to ensure that personnel fully understand relevant matters, processes and crisis response, so as to enhance compliance awareness of all personnel, reduce practical errors and promote stable operation of enterprises. Integration suggestions: Education and training needs to cover personnel at different positions and levels, regularly or irregularly, in various forms, and form a long-term mechanism. Special attention should be paid to the retention of training materials, which should be recorded in electronic, paper, photos, videos and other means. The content should include training date, personnel and relevant content materials, especially for enterprises that plan to apply for AEO certification or have been awarded AEO certification, so that they can be submitted as soon as possible in application or review. (VII) Information and data management Brief comments: Compliance guide and Customs AEO certification standards require the retention of relevant materials, and put forward compliance requirements for the management of documents, data and other materials and archives. The compliance guide are mainly based on fixed records and evidence, and the retention period is at least five years. AEO certification standards emphasize the application of information systems, which is also the conditions for enterprises to apply for AEO certification. The core is that information and main links of import and export activities can be recorded, traced, inquired, analyzed and warned through the system, and the storage period is at least three years. Integration suggestions: If conditions permit, enterprises can use information systems to effectively control production and operation, import and export activities, financial data, etc., in order to meet both requirements. Personnel are required to strengthen the awareness of evidence, and the handling personnel should record and report the important matters through telephone, interview and other means. The retention and filing of documents, data and other materials shall meet the requirements of the minimum time limit. Conclusion 1.Both the Compliance Guide of the Ministry of Commerce and the AEO certification standards of the Customs are essentially the guiding opinions or audit standards proposed by the competent authorities in their respective supervision fields for enterprises’ compliance operation and establishment of internal compliance mechanisms, which have important guiding significance for enterprises’ establishment of internal compliance mechanisms. 2. In reality, the relationship between enterprises and regulatory authorities is often “one-to-many”. The same enterprise needs to meet the compliance requirements of different departments at the same time. For enterprises, embedding relevant requirements under the existing system and management framework is an effective way to improve management efficiency. This note provides suggestions on the integration of Compliance Guide and Customs AEO certification standards. 3. The attitude and actions of an enterprise towards compliance are best presented in a visual way, such as issuing high-level policy statements, formulating work systems and business processes, adding relevant posts or full-time personnel in the organizational structure, and issuing compliance manuals. These actions not only show the compliance achievements of the enterprise, but also serve as evidence for the company to fulfill its compliance obligations, and contribute to personnel training and actual implementation.
