What's Happening?
Subaru of America (SOA) is actively enhancing its export compliance activities to adhere to all U.S. export regulations, as detailed in a job description for an Export Trade Compliance Manager. This role involves setting, implementing, and overseeing
policies and procedures to ensure compliance with regulations from entities such as the U.S. Bureau of Industry and Security (BIS), U.S. Census Bureau, U.S. Office of Foreign Assets Controls (OFAC), and U.S. Customs and Border Protection (CBP). The company aims to minimize exposure to penalties by monitoring regulatory changes, updating policies, and disseminating relevant information to stakeholders. A key focus is spearheading compliance activities for the BIS Connected Vehicle Rule, which includes establishing an internal task force and collaborating with Subaru Corporation (SBR) and other internal and external partners. The manager will also be responsible for determining Export Control Classification Numbers (ECCNs) for new technologies in future vehicle models and 'one-off' export shipments, researching license requirements, and managing export licenses.
Why It's Important?
This initiative by Subaru of America is crucial for maintaining its operational integrity and reputation within the highly regulated U.S. automotive market. Strict adherence to export compliance regulations is vital to avoid significant financial penalties, legal repercussions, and potential disruptions to its supply chain and distribution networks. By proactively managing its compliance program, SOA safeguards its ability to import and export vehicles and parts, which is essential for its business model as a leading auto brand in the U.S. The focus on the BIS Connected Vehicle Rule highlights the increasing complexity of regulations surrounding advanced automotive technology and data, underscoring the need for robust internal controls. Furthermore, a strong compliance framework fosters trust with government agencies and international partners, ensuring smooth trade operations and supporting Subaru's commitment to being 'More Than a Car Company' through responsible business practices.
What's Next?
Subaru of America will continue to integrate its enhanced export compliance measures across all departments, including off-site locations and the Legal department, providing guidance and operational support. The company plans to maintain its online Export Control Awareness Course, determining job functions that require training and coordinating with Human Resources to assign it. Regular updates to the SOA Export Compliance Manual will reflect regulatory changes. The Export Trade Compliance Manager will also lead and manage a team of export professionals, overseeing the accuracy of Electronic Export Information (EEI) filings and assisting in Global Trade Management (GTM) system enhancements. Collaboration with North American Subaru, Inc. (NASI) Government and Regulatory Affairs in D.C. will be ongoing to address proposed regulations affecting the automotive industry from an export control perspective, ensuring Subaru's voice is heard in policy discussions.
Beyond the Headlines
The intensified focus on export compliance by Subaru of America reflects a broader trend of increasing scrutiny and complexity in international trade regulations, particularly concerning advanced technology and supply chain transparency. The emphasis on the Uyghur Forced Labor Prevention Act (UFLPA) working group with SBR and Subaru of Indiana Automotive (SIA) points to the growing importance of ethical sourcing and human rights considerations in global supply chains. This goes beyond mere legal compliance, touching upon corporate social responsibility and brand image. The need to determine ECCNs for new technologies in future vehicle models also highlights the dual-use nature of many modern automotive components, which can have both civilian and military applications, thus falling under stricter export controls. This proactive approach by Subaru could set a precedent for other automotive manufacturers in navigating the intricate web of U.S. export controls and ethical trade practices.
