orchid advisors tmorchidadvisors.com/...ecosystemmethodology_2014.pdf · the firearm compliance...

Transforming The Compliance EcosystemOrchid AdvisorsTM

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Spotlight On: Orchid White Paper SeriesThe Firearm Compliance EcosystemTM

January 2014

Spotlight On: Orchid White Paper SeriesThe Firearm Compliance EcosystemTM


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Copyright ©2014 Orchid Advisors.

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The Firearm Compliance EcosystemTM 1

Building a Compliance CultureTM is a long-term commitment to corporate stewardship, business ethics, and managed enterprise risk. It is not a one-time event. It is not limited to one part of your business. It is, truly, an organization-wide, sustained effort that becomes a part of your organizational structure from Human Resources, to Finance and Accounting, to Manufacturing Operations. It doesn’t go away after an inspection and is embedded and continuously improved as your business and the regulatory environment evolves. “Being compliant” should be an ever-present mantra that becomes part of your company’s core values.

Getting there from here entails taking purposeful, but measured, steps – some strategic, some tactical; some human-oriented, some technical; some proactive, some pre-planned reactive. Orchid Advisors encap-sulates these steps into its “Compliance EcosystemTM” framework – a four-phased, multi-disciplined effort that culminates with an integrated, sustainable Compliance CultureTM for your firm.

The industry is raising the line of sight of compliance initiatives – on par with other key metrics such as profit and safety. Think of this as the evolution of product and manufacturing quality from basic operations to leading Japanese principles.

If you want to know more about modern, technology-aided ATF compliance throughout the firearms industry, read the Orchid White Paper “Firearms Industry Compliance – Leading Best Practices.”

Introducing the Orchid AdvisorsCompliance EcosystemTM Framework

Understanding The ComplianceEcosystemTM Framework

Orchid Advisors’ Compliance EcosystemTM framework has four main elements that span the entire supply chain – from the vendors, to manufacturers, to distributors and retailers.

The key elements include:

Aligning corporate and regulatory compliance with business strategyIntegrating compliance into the culture and establishingminimum levels of literacyEnabling business processes with best-in-class technology; andContinuously monitoring and improving transparent operations

These four elements are shown graphically in Figure 1. Orchid has product lines associated with each of these four columns.

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Suppliers Customers

Sustained Monitoring& Improvement

Measure With Audits, Industry Benchmarking

and Data Analytics

Govern with Executive Dashboards

Stay In-Tune withIndustry, Legal and

Political Trends

Compliance ProgramStrategy

Map Your EcosystemAnd Regulatory

Environment

Build Your Compliance Vision and Integrate

with Business Strategy

Map Your Federaland State Relationship

Strategy

Re-define Cultural Norms, Policies and Expectations

Establish StructuredRoles, Ownership

and KPIs

Certify and Deliver Knowledge Throughout Your

Ecosystem

CulturalTransformation

Process & TechnologyEnablement

Drive Repeatability with Lean Six Sigma and Internal

Controls

Integrate ERP, CRMand Advanced Technologies

Control ThroughChange and Project

Management


TM

Strategy mapping synchronizes your business and regulations. Culture drives literacy and behavior throughout. Technology enables transaction accuracy. Continuous improvement provides real-time visibility to manage your compliance. These four core elements work in tandem. Failure to address any one of these inside your organization, and in some cases throughout the entire Compliance EcosystemTM (i.e., a sole sourced

Figure 1: The Four Core Elements of Orchid’s Compliance EcosystemTM Framework.


supplier or distant sales agent) can have a powerful effect.

The rest of this white paper is focused on drilling down into each of the four phases, and understanding the activities of each. Over the following pages, we’ll give examples of how Orchid Advisors and emerging industry leaders in firearms compliance have demonstrated excellence in each one of these categories.

Aligning Corporate and RegulatoryCompliance with Business Strategy

Too many companies have a myopic vision of compliance and that’s what gets them into trouble. Compliance isn’t a department; it is a way of conducting business, strategically. The first phase of Orchid Advisors’ Compliance EcosystemTM methodology addresses the broader, strategic needs of a CEO or General Counsel – the Strategic Mapping of the entire business to the regulatory environment.

Your business relies on compliance and visibility throughout the ecosys-tem – manufacturers, suppliers, licensees, distributors, retailers, and other partners. And, your relationship with the Federal and State government are what you make of it. How you interact with your regulators is up to you – but there is strategy involved. Some draw a hard line and limit transparency while others are an open book. Both have their advantages and disadvantages. Defining your approach and knowing the positives and negatives of each are key to navigating complex regulations. In con-trast, operating in a grey area to avoid decision-making only creates more risk for the business enterprise.

For example, Federal and State regulations change and so does your business. New markets may be served, channel partners added, distribution models change, and products evolve. Sustaining a compliant ecosphere requires an understanding of where your business is headed, what regulations may apply now and in the future, and planning for development and strategic risk-taking. Do you have new products being introduced in new markets? Are existing products changing? Does compliance know and are they being registered with state agencies? How does your change management integrate ATF compliance and business evolution?

With all this change, mistakes are still likely to happen. It’s your job to mitigate the risk of the material events with a sound compliance program that is tangible and defendable. So, how do you establish an effective environment that also provides a meaningful defense in the event of unplanned litigation? Section 8B2.1 of the U.S. Federal Sentencing Guidelines1 defines the criteria for an effective compliance and ethics 1 http://www.ussc.gov/Guidelines/2012_Guidelines/index.cfm


program. Core to those guidelines is the differentiation between “being compliant” and managing a “compliance program.” The following areas transcend compliance with every regulation from ATF Compliance, State Firearm Compliance, Import/Export Compliance, Anti-Corruption/Anti-Bribery, or any other regulation.

Remember, how you interact with your regulators is up to you – but there is strategy involved. As mentioned above, some draw a hard line and limit transparency while others are an open book. Both have their advantages and disadvantages. Defining your approach and knowledge the positives and negatives of each are key to navigating complex regulations.

Defined leadership, ownership and organization structureDocumented and known policies and proceduresEffective training and promoting a supporting cultureOngoing efforts to prohibit engaging in business with prohibited personsIndependent monitoring of both your transaction activityand program effectivenessMeasurable accountability, investigative support and a commitment to hold accountable

Success StoriesPrepped and Guided the Largest of U.S. Federal Firearms License Holders Through a Major ATF InspectionWe provided executive management with a roadmap to regulatory success. Faced with the largest inspection in many years, their multiple FFLs were pending review for compliance with the Gun Control Act, National Firearms Act and Arms Export Control Act. Orchid developed a custom project plan that included a pre-inspection gap assessment, a mock inspection to determine what the ATF might find (within material limits), a remediation plan, and regulatory liaison support.

The result: Like all of the FFLs that Orchid has served, our client passed the inspection without a warning conference or revocation. In fact, our ATF Compliance solution has led them to an informal industry leadership level of status.

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Transformed Compliance EcosystemTM in Wake of Largest DOJ/SEC FCPA Investigation in IndustryWe transformed key elements of client’s Compliance EcosystemTM in the wake of one industry’s largest and most prominent FCPA investigation under the direction of the U.S. DOJ and SEC. The future-state program was deployed across the client’s entire ecosystem – from in-city suppli-ers to sales channel partners located in Japan. It included a compliance program strategy, a holistic re-design to the client’s employee training platform, the implementation of software application controls, and its first ever Internal Audit program. The new compliance ecosystem not only met the expectations of 8B2.1 FSG, but also provided the execu-tive team with visibility into its evolving international business, allowing proactive decision-making pertaining to the use of distant, third-world channel partners. The result: Satisfied regulators, managed enterprise risk on a global basis.

Critical Suppliers Educated and Evolved to Best-in-Class Through Orchid Supplier Readiness ToolsWe focused our compliance efforts on high-risk, single-point-of-supply-chain failures to significantly reduce production risk. Our team was hired to host a supplier compliance conference. We educated sole-source and multi-source suppliers of key components on high-risk regulatory concepts and enhanced the supplier-buyer collaboration process. Supplier agreements were modified to include minimum compliance standards and a right to audit clause. One key supplier was chosen for a year-long regulatory overhaul that consisted of compliance advisory, project management, and implementation. The result: A more transpar-ent supplier-buyer relationship with focus on compliance as an additional consideration in decision-making.


Integrating Compliance Into the Culture and Establishing Minimum Levels of Literacy

Best-in-class companies drive compliance from the top and the middle of the organization. Cultural adaptation is powered by this broad under-standing and distributed ownership among key elements throughout your compliance ecosystem. This includes consideration and reinforcement of compliance in transaction level activities, job descriptions, and performance metrics. How does that happen?

With formal education. Setting a minimum level of compliance literacy is one of the most impactful activities for enhancing your overall ATF compliance. How do you expect employees to comply if they don’t know the rules? Do you know the rules?

Regulations are complex and require an understanding of what was, what is, and what could be. Regulations are changing rapidly, and staying on top of the requirements necessitates a minimum level of literacy from the CEO’s office to the production line employee who is engraving the serial number on your firearms. Orchid Advisors is leading the firearms indus-try to new levels of compliance education with on-line, on-demand training, and certifications that give you comfort that your broader enterprise has a minimum level of understanding.

The First Firearms Compliance UniversityToday, retailers, distributors, wholesalers, and manufacturers are all expected to know just about everything there is to know about firearms compliance. Down to the nitty gritty footnotes on regulation rulings. It’s a tall order. It is especially taller when one considers that there is no consistent, systematic education available that spans the range of infor-mation required by various authorities. While some basic, occasional in-person seminars exist from former ATF inspectors about some facets of firearms compliance, there has been no multi-level, multi-modal education curriculum to teach everyone from warehouse workers to Chief Compliance Officers. Today, retailers, distributors, wholesalers, and manufacturers are all expected to know just about everything there is to know about firearms compliance. Down to the nitty gritty footnotes

on regulation rulings. It’s a tall order. It is especially taller when one considers that there is no consistent, systematic education available that spans the range of information required by various authorities. While some basic, occasional in-person seminars exist from former ATF inspec-tors about some facets of firearms compliance, there has been no multi-level, multi-modal education curriculum to teach everyone from ware-house workers to Chief Compliance Officers. Until now.

Domestic Federal and State firearm regulations;International Federal regulations that govern global firearms trade which includes Import, Export/ITAR and Anti-Corruption/ Anti-Bribery topics; and,Advanced levels of knowledge required to design and manage best practices-level firearms compliance programs in accorancewith government expectations.

The training is delivered in on-line video and in written text/workbook formats. (See Figure 2)

On-Line Training for EmployeesOrchid also sources and implements curricula for corporate training on basic compliance concepts such as Sexual Harassment, Conflicts of Interest, Appropriate Social Media Use, Insider Trading and much more. These are available on-line or embedded in leading corporate training platforms such as the following and others not listed.

Orchid Advisors’ Firearms Compliance Certification Program offers both “awareness level” coursework and “detailed certifications” for those whoneed to manage compliance at their firm. Topics include:4

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Figure 2: Orchid’s Industry-Leading Educational Programs.


LRNSuccessFactorsSABACogentysWeComply

Orchid today is the leading resource for compliance education for the firearms industry.

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Figure 3: On-Line Universities for Clients.

Figure 4: On-Site Training for Clients.

We transformed a global compliance culture to exceed the expectations set forth in the U.S. Federal Sentencing Guidelines 8b2.1. The program created a new cross-function leadership structure focused on the enterprise management of risk, ethics, and compliance. New employees receive on-boarding training and roles, responsibilities, MBOs, and job descriptions were modified to change behavior. Best-in-class on-line policies repositories and a new policy/procedure methodology were implemented. (See Figure 5) In addition, corporate awareness campaigns were launched throughout the company focused on compliance and ethics awareness. (See Figure 6)

The Result: A complete elevation of the minimum literacy levels and new organizational ownership for compliance company-wide.

Figure 5: On-Line Policy Systems.

Success StoriesTransformed Compliance Culture

Additional activities included the sourcing and implementation of a global, on-line, on-demand training university for its suppliers, employees, and international channel partners. The Result: Compliance fully integrated into every facet of the client’s business culture.


Implemented Best-In-Class Learning Management Systems(e-Learning/Online University) and In-Person Global Ethics and Compliance TrainingWe implemented best-in-class training across multiple facilities by implementing online training universities offered by leading providers. The training effort included, among other things, The Impact of Ethics; Ethics Defined and Pertinent Regulations; Cornerstones of Ethical Conduct such as Anti-Bribery/Corruption, Improper Acts, Conflicts of Interest, and Gifts/Gratuities; and, Establishing a Culture of Integrity. The training concluded with tests of personnel understanding to underscore the importance of such behavior.

The Result: Best-In-Class sustainable minimum literacy levels on key ethics and integrity training.

Figure 6: Corporate Ethics Awareness Campaigns.

Enabling Operational ATF Transactions with Best In Class Technology

Compliance isn’t the result of a successful transaction – it is the result of continuous activity that exists in multiple processes throughout your organization. Designing processes to a near fail-safe limit reduces the risk that surprises will take you off guard and result in a violation.

At Orchid, we are all about making transformative change through intelligent business process re-engineering and management – and technology necessarily plays a fundamental, supporting role in that process. We work side-by-side with your technical team, to achieve sustainable business compliance goals, to yield a proactively-prepared environment for compliance.

Think about it, change happens – every day. What changed today that you aren’t aware of? Has operations asked IT to reconfigure the programming in your logistics software? Did a lean management consultant come in and remove WGIG controls to speed processing? Maintaining compliance in operational areas requires full integration of compliance into business change management concepts to limit risk.

Many firearms industry firms are still using legacy computer systems to process ATF-related transactions. They may run well and you may be comfortable. Legacy systems are similar to a well loved Pinto that has been duck-taped at each critical joint to the owners’ chagrin. You may not want to part with it because it is just so comfortable. Is that really a long-term viable option for your corporate enterprise when subject to evolving ATF regulations and expectations?

Orchid Advisors has designed a custom extension ATF Compliance solution – the first in the industry – to enable your environment with advanced technology and integrated application controls. We’ve gone so far as to embed logic into injection molding machines to drive synchro-nization between asset creation and the regulations. We wonder if your current regulatory consultant or legal advisor can do that!?

Orchid Advisors currently has professional developer and services


relationships with:

and is adding other technical partners all the time. Orchid is the leading resource for ATF compliance technology strategies and solutions for the firearms industry.

Success StoriesDesigned first US installation of SAP for firearms Compliance in the United StatesWe designed a multi-facility ERP system (using SAP software) to control all aspects of ATF Compliance and serial number control across multiple facilities. The implementation provided industry leading internal controls that limit the risk of compliance error for millions of annual transactions. Both Manufacturing and Compliance personnel were provided real-time visibility via dashboard reporting into the state of their firearms compliance. And, Operations personnel further gained real-time visibility into the exact location of serialized assets throughout their multiple facilities on a moment’s notice.

The Result: An end-to-end ATF Compliance system that spans internal and partner systems that enables extensive compliance visibility and monitoring.

Serial Number Validation/Creation of a Closed Loop Serial NumberControl System For Major Injection Molding ManufacturerThe accuracy of Serial Number recording in the A&D Book and ensuring that the engraving meets ATF specifications is dependent upon many factors. To drive the highest levels of accuracy, we designed “dual-blind-entry” technology to ensure that the product identification match the serial number engraved on the firearms. On the paper hang tags the human readable number was removed so that only the bar code remains. Scanning software requires dual entry at key transaction points. The user must scan the barcode serial number on the hang tag into the system followed by a hand key of the human readable serial number as engraved on the firearm. The system must match the two serial numbers in order for the transaction to proceed. Daily system reports were created to balance the number of serial numbers lasers – to items produced – to vaulted – to shipped.

Integrating Compliance and the New Product Development Cyclefor a Major Consumer Products Manufacturer

Injection Molding Integrated with Software Logic for Major Injection Molding Manufacturer

We used technology to integrate a Client’s firearm products with its regu-latory environment to minimize sale disruption. A system-based work-flow was configured in the Product Management System (PMS) to force the inclusion of compliance oversight prior to pilot production. As a result, the legal department was provided a current state map of products-to-regulations. Thereafter, the legal department maintained visibility into the Client’s evolving ecosystem through knowledge of each change in firearm form, fit, or function, and can now properly register firearms in requisite states.

The Result: Sustainable, open flow of products to key markets.

We implemented the industry’s first “shot-scan-shot” programmed logic-controlled technology. The objective of this effort was twofold: to ensure that no firearm could ever be molded without entry into the A&D book, and that for every acquisition in the A&D, an actual, physical firearm was produced – i.e., no creation of ghost assets.

The Result: A reduction in ghost assets and confidence in A&D entries through a new control point for transaction tracking.


Continuously Monitoring and Improving Transparent Operations

In order to truly be in control of your Compliance EcosystemTM, you need to know where your key performance indicators stand, what is happening in your supply chain and the industry at large, and what the world is saying about it. You want to know at the earliest stages of any social feedback over actions by your firm -- so you can do something about it aggressively and early.

What’s needed is complete and real-time visibility into internal and external factors impacting your brands and operations. Proactive compli-ance is further enabled with predictive analytics and prospective monitor-ing. It’s a fairly basic choice for you: Do you want to find problems and fix them, or would you rather leave that up to your regulators during an inspection? We think the former is preferable. Would you like to know as soon as possible that one of your guns was involved in a national press-covered event, or wait until you see it on the news? Reacting quickly to emerging issues will help bolster the impression that you are in control of your company and able to respond with all your assets.

Finding issues and predicting problems requires lots of hooks into your systems and processes in order to be able to track, measure, and find problems. Transparency is key and that requires structured audit programs to monitor, measure, and correct, as a way of conducting business. While Internal Audit is a valuable but necessary evil, the future is real-time executive dashboards that alert you of compliance errors as they happen – or predict that they are coming. That provides the lowest risk proposition for identifying and correcting problems. Would you like real-time insight into the state of your compliance? Of course you would. And tracking trending issues in the external world requires hooks into major feeds and sources of information that provide you with news, analysis, regulations, facts, and other items of interest – in real time. Wouldn’t you like that on your dashboard as well?

Orchid Advisors provides the most technologically integrated and forward-looking visibility solutions on the market today for your compliance needs.

Success StoriesDevelopment of Independent Governance, Monitoring and Continuous Improvement

Best-in Class Physical Security Design at a Regulated Consumer Products Manufacturer

We implemented more than one Internal Audit department from scratch. And, we’ve re-engineered several more for mid-to-large cap organiza-tions. The key to success? Creating a function that aligns independent governance to help achieve strategic objectives while limiting financial, operational, legal and reputation risk. Our best-in-class programs have included real-time dashboard systems that provide finance, operations and compliance personnel with the ability to report on, or actively see, issues within their compliance system.

The Result: Real time response and correction of business and regulatory issues.

All preventative and detective measures of physical security were enhanced to significantly limit or prevent the risk of theft. These mea-sures include a “box within a box” security structure. By definition, the building and the firearm operations areas were secured with best-in-class security features.

Personnel and vehicle flow significantly re-engineered as well as con-tractual obligations and logistics scheduling

Card keys are required to enter every point of the facility; there are no open access points

Exterior doors have timed and audible alarm features

Non firearm trash is inspected by security personnel by emptying it into another container while being inspected; firearm scrap is removed in sealed, black bags

A third party security force has been assigned to monitor transaction activity in and out, 24 hours per day; only one individual may pass at a time and they must remove all non-clothing related assets (laptops, lunch bags, etc.) which are inspected by security and then the person is subject to a full metal detector review.

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Access to vaulted areas secured to only allow individuals with required access

Individual boxes of completed products are sealed with security tape and are stacked on pallets and then wrapped in clear plastic shrink wrap; labeling is non-descript

The Result: Tighter control over all ingress/egress points, resulting in better controls and measurable impacts on metrics.

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Why Orchid? Why Not Internal Staff?

Orchid Advisors is pioneering and transforming the concept of a Compliance EcosystemTM – that is, the compliance activities that exist throughout your supply chain, from manufacturers, to distributors, and to the end consumer.

We are a strategic management consultancy, akin to McKinsey, BCG and Big 4 firms delivering services for the strategic needs of a CEO, CFO and General Counsel. We leverage Orchid’s thought leadership, technol-ogy and software to innovate your compliance. And, we leave simple regulatory recital and checklist-based services to our competition.

We work alongside your staff and complement their efforts. Our goal is to leave in place an elevated Compliance Culture. While internal staff has an extensive array of knowledge, history, and experience with the Compliance activities in your firm, Orchid brings technical specialty and regulatory domain knowledge that results from our continued exposure to many environments and situations – including many instances of mediat-ing solutions for clients with the ATF and other regulators. If you reduce this to an internal v. external consultant battle, we all lose. The bottom line is we all have something to add to the equation, and all our respective talents are needed to re-invent Compliance.

What Next?Schedule time with our executive management with your executive man-agement. We can discuss how working together we can take Compliance in your firm to a next level.

The time to act is now. Let us help make Compliance a non-issue in your firm.


About Orchid Advisors

Products and Services

Orchid Advisors is a strategic management consultancy focused on transforming the worlds of audit and compliance. We are experts in ATF Compliance, State Firearms Compliance, Anti-Corruption/Bribery, ITAR, Import, Export, and Sarbanes-Oxley. Our initial entry market is the Firearms Industry where Orchid counts among its customers the top manufacturers in the world. Orchid clients hire the firm to reinvent busi-ness processes, implement technology and big data solutions to support that change, and transform their compliance culture. Orchid Advisors brings the depth and breadth of Big Four consulting with the innovation, thought leadership, and economies of a boutique analyst firm. More information about our four service lines of Compliance Consulting, Technology, Business Consulting and Internal Audit may be found at www.orchidadvisors.com.

Compliance Program StrategyCultural TransformationProcess & Technology EnablementSustained Monitoring & ImprovementInspection Readiness & RemediationSupplier & Channel Partner ReadinessCorporate Compliance & Ethics TrainingPhysical SecurityFirearms Industry Certification ProgramCompliance Technology, Data Analytics and ExecutiveDashboardsBusiness ConsultingERM, SOX and Internal Audit

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Our OfficesOrchid Advisors is headquartered in Hartford, CT with technology research and development offices in East Hartford, CT.

Orchid Advisors Headquarters:100 Pearl Street, 14th Fl Hartford, CT 06103 United Statestel: +1 (855) ORCHID-0 fax: +1 (800) 507-4409 East Hartford R&D Offices:Orchid Advisors Connecticut Center for Advanced Technology (CCAT)222 Pitkin StreetEast Hartford, CT, 06108United Statestel: +1 (855) ORCHID-0fax: +1 (800) 507-4409


How Orchid Advisors is Reinventing ATF Compliance with Innovative Technology Solutions

FFL-to-ATF EZ Check MatchSoftware controls prohibit order entry or product shipment by comparing customer FFL and the ATF’s EZ Check database.

Segregated Scrap ControlScrapping a firearm and disposition from the Book of A&D requires system IDs from two separate departments and are complemented by a balancing report ensuring items to-be-scrapped were completed.

Variance Receipt ValidationSystem data tables mirror paper ATF variances, reserving serial numbers by suppliers and model, and notifying operators when an off-variance serial number is received.

Firearms Compliance UniversityOn-demand courses train operators through executives on ATF, Import, Export, and FCPA regulations and provide best-practice internal control examples.

Dual Blind EntrySoftware logic requires independent, dual-entry of a serial number at every transaction point via hand-key, 1D/2D bar code, or Optical Character Recognition to enhance integrity of A&D Book. Real-Time Acquisitions and DispositionsModern dash-board and query technology that enables any authorized employee to slice and dice the A&D Book – on a real time basis – for regulators or for internal audit purposes.

WGIB (Wrong Gun In Box) 3-Way MatchWGIB risk mitigated by limiting the print of box labels to only those transactions with a combined dual-blind entry and product weight check.

Acquisition and Ghost Serial Number ControlIntegrated programmable logic controller and injection-molding machines require sequence and phased timing, called “Shot-Scan-Shot-Scan.” Software mitigates the risk of ever producing a ghost serial number.

Real-Time Compliance Tracking and NotificationsSoftware identifies possible transaction errors in real-time and sends workflow notifications to the Compliance Department as they are detected. For example, prior theft-loss received on a customer return.

Import Match And DecrementElectronic import licenses that limit buying to make, model, type, and quantity of firearms or as stated on approved import licenses.

Bidirectional Independent Serial Number InventorySoftware application that reconciles physical product count to scanned serial numbers the Book of A&D by segmented areas of your factory, retail operation, or national sales team – and then again in reverse.

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