1 / 12

Schlumberger Trade Control Compliance

Schlumberger Trade Control Compliance. By: Khalid Javed Date: May 2004. Agenda. Schlumberger TCC Department Role of TCC Department TCC Programs Training & Awareness SATCP TCCAR Country Reviews. Trade Control Compliance Department Organization. Shannon Poskevich

anne
Download Presentation

Schlumberger Trade Control Compliance

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Schlumberger Trade Control Compliance By: Khalid Javed Date: May 2004

  2. Agenda • Schlumberger TCC Department • Role of TCC Department • TCC Programs • Training & Awareness • SATCP • TCCAR • Country Reviews

  3. Trade Control Compliance Department Organization Shannon Poskevich Global Trade Control Compliance Manager Area Legal Counsel Amel Meddour TCC Program Coordinator WesternGeco General Counsel ECA Aicha Lahcene TCC Analyst MEAKhalid Javed TCC Analyst NSA Jaime Torres TCC Analyst WesternGeco Martin Wiltshire TCCO Manager WG TCCO Team MEAAssouane Gzara Technical Advisor

  4. Role of TCC Group • Key Management Objectives • Interpret Law and Implement Guidelines • Interact with Government regulatory Authorities • Training & Awareness • Product Development • Country, Site Reviews & Self-Assessment Program • Record Retention Process • Hiring and Transferring of Foreign Nationals

  5. What is TCC Group Dealing With? Operations: • Government product licensing (software & hardware) • Assist with tender when trade issues are identified • Training & Awareness • Compliance w/ license conditions • Government end-user visits • Software de-minimis filings • Approve compliant standard software images • Maintain InTouch TCC helpdesk • US Customs Audit – Follow-up Technology Centers: • TCC role in Product development

  6. What is TCC Group Dealing With (Cont.) Technology Centers (cont.) • Transfer of technology (joint development projects, posting on Intranet) • Employment of foreign nationals • Obtaining outside legal opinion where deemed necessary (e.g., OSLC) Legal Department: • Risk Analysis • Interpretation of regulations • Training of Jr. Lawyers • Identifying and maintaining outside Legal Counsel(s) contacts with proper identified expertise Schlumberger Supply Chain Services (SSCS): • Guidelines for movement of tangible goods (import & export) • Assist in selection of brokers and freight forwarders • Developing SLB Import Compliance program • Job Descriptions to include TCC measures

  7. What is TCC Dealing With (Cont.) Personnel: • Hiring and transferring of US and foreign nationals Oil Company Clients: • Meet and present to client, Schlumberger TCC organization and program Corporate SL: • Ensure TCC program for SLB meets Sarbanes Oxley requirements • Developing SLB TCC Training Program IT Hub Management: • Transfer of technology and posting of information to Intranet • Training of Contributors (Tagging info for TCC) InTouch: • Transfer of technology & TCC Classification of documents • Training of publishers (Tagging info for TCC)

  8. Training & Awareness • Technical expert and liaison for field operations • InTouch TCC Help Desk Management • Training and awareness for all field locations and managers • On-Site Visits, NetMeeting, Country Booklets • Web based Mandatory minimum training • Annual Recusal Program for US Persons • Identify risk areas and escalate issues to proper management level

  9. TCC Programs - InTouch Help Desk • Provide trade compliance “technical support” to Schlumberger personnel via InTouchSupport.com • TCC personnel are InTouch Engineers (ITEs) • Screening and classification of Field Assessable Knowledge base • Rolled out in July 2003. • 204 tickets closed by Dec 2003 (150 from MEA)

  10. TCC Programs - SATCP • Self Assessment Trade Compliance Program • Tool for local management to assess trade compliance status and monitor improvements • Available on-line through Quest • Workbook with targeted questionnaires / scorecards • TCC assists local management with oversight and implementation

  11. TCC Programs -TCCAR • Trade Control Compliance Assurance Review • Tool for TCC to assess trade compliance status of selected sites (TCCAR) • Comprehensive review of procedures, transactions, and documents • Utilizes QUEST for follow-up and closure • Sites selection factors include SATCP score, risk, and recent trade issues, and management request

  12. TCC Programs –Country Review • Tool for TCC to assess trade compliance status of selected countries (One Review per year) • Comprehensive review of procedures, transactions, and documents, involving all sites having transaction with the country e.g. Suppliers (Internal / external), logistics hubs etc.. • Detailed In-Country Audit including interview, review of documentation, physical verification of assets • Utilizes QUEST for follow-up and closure, involves follow-up with external sites

More Related