Draft Trade Compliance Policy For International Sales Operations

---
name: its-draft-trade-compliance-policy-intl-sales
task_id: international-trade-sanctions/draft-trade-compliance-policy-for-international-sales-operations
description: Drafts a trade compliance policy for international sales operations that addresses deficiencies identified in the company’s warning-letter correspondence and gap assessment, covering deemed export controls, anti-boycott reporting, jurisdictional boundary procedures between export-control regimes, foreign-produced item content analysis, and technology control plan requirements.
activates_for: [planner, solver, checker]
---

# Skill: Draft Trade Compliance Policy for International Sales Operations

## 1. Subject-matter triage
- Draft a standalone trade compliance policy for international sales operations, not a memo or issue list.
- Read the warning letter, gap assessment, and supporting documents as the source set for required policy provisions.
- Map each identified deficiency to an operative policy rule, procedure, owner, training obligation, and records requirement.
- If the source set spans multiple regimes, counterparties, destinations, product lines, or reporting channels, address each distinctly rather than using one generic compliance paragraph.

## 2. Failure modes the skill is correcting
- Addressing only the most visible deficiency and leaving other identified gaps unresolved.
- Collapsing distinct reporting obligations into one procedure when different laws, agencies, forms, triggers, or deadlines apply.
- Drafting jurisdictional-boundary language that is too abstract to be executable by sales, compliance, or operations personnel.
- Omitting interim controls while a classification, jurisdiction, or licensing determination is pending.
- Failing to translate technical export-control analysis into a practical workflow for foreign nationals, screening, escalation, and documentation.
- Writing a policy that sounds compliant but does not assign responsibility, training, monitoring, or escalation steps.

## 3. Legal frameworks / domain conventions that apply
- Deemed export controls: when access by a foreign national to controlled technology may trigger licensing review, the policy should require a technology control plan, identity and role review, nationality and destination screening, and pre-access clearance under the applicable export-control regime.
- Anti-boycott compliance: boycott-related requests can trigger separate reporting duties under different statutory and regulatory regimes; the policy must treat each reporting stream independently and specify the triggering conduct, responsible function, filing path, and timing.
- Restricted destinations and counterparties: sanctions, embargo, and restricted-party rules require pre-transaction screening and hold procedures before shipment, service, financing, or facilitation proceeds.
- Jurisdictional boundary determinations: where it is unclear which export-control regime governs an item, the policy should require a formal classification or jurisdiction-determination process before reliance on a final designation.
- Foreign-produced item analysis: if foreign-produced items may be captured through U.S.-origin content, U.S. equipment, or U.S. technology inputs, the policy should specify the applicable content analysis method, threshold review, and licensing consequence.
- Denied-party and watchlist screening: use the applicable consolidated screening resources and require escalation of false positives, true hits, and matches requiring additional review.
- Defense-related flow-downs, if implicated by the source set: include supplier/customer certification, audit-rights, and downstream compliance obligations tied to the transaction structure.

## 4. Analytical scaffolds
- Start by identifying every deficiency, risk area, or required control in the source documents, then draft a corresponding policy section for each one.
- For each section, state: the legal requirement, the company rule, the procedure, the responsible role, the training requirement, and the documentation or retention requirement.
- Separate front-end screening, midstream escalation, and post-transaction reporting so the workflow is operationally usable.
- For deemed exports, specify when intake must flag a foreign national issue, what information is collected, who reviews it, when legal or compliance must clear access, and what controls apply before access is granted.
- For anti-boycott matters, create distinct provisions for the different reporting regimes and require personnel to recognize boycott requests and route them immediately.
- For jurisdictional uncertainty, require a hold on affected activity until the determination is complete and recorded.
- For foreign-produced item analysis, require a documented methodology, input collection from business teams, threshold testing, and licensing review if the analysis crosses the applicable line.
- For screening alerts, require triage, escalation, disposition, and documentation of the result.
- If the source set refers to customer- or product-specific flow-downs, include the contractual or certification controls that preserve compliance through the supply chain.

## 5. Vertical / structural / temporal relationships
- Build the policy in the order an international sales team would encounter issues: screening first, then classification and jurisdiction, then technology access, then shipment or service approval, then reporting and retention.
- Distinguish internal decision points from external filing or notification points.
- Where a determination depends on an upstream classification, require the upstream step before the downstream activity can proceed.
- Where multiple regulatory regimes may overlap, state which step controls first, which step runs in parallel, and which step may only occur after clearance.
- Treat pending determinations as a temporary stop state, not as an implicit approval.

## 6. Output structure conventions
- Draft as a complete policy with industry-conventional headings, not as a checklist or legal analysis.
- Use sections that naturally cover purpose, scope, definitions, roles and responsibilities, screening, classification/jurisdiction, deemed exports and technology controls, anti-boycott reporting, foreign-produced item analysis, restricted parties and destinations, escalation, training, records, audits, and enforcement.
- Under each major heading, include the operative rule, procedure, training expectations, and monitoring/documentation requirements.
- Cross-reference each policy provision to the specific warning-letter or gap-assessment issue it addresses, without reproducing internal wording.
- Use precise, directive language: “must,” “may not,” “shall,” “requires,” and “is prohibited” where appropriate.
- Cite controlling legal authorities, regulations, or agency guidance when stating a legal requirement, and do not assert compliance conclusions without naming the rule that supports them.
- End with a short implementation or approval section if needed, but keep the policy itself as the primary deliverable.