Penalties. Stateside the fine can land on one person, so one person gets the title. Germany names the job: Exportkontrollbeauftragter.
Bev has the mechanism right. I would restate it one level up: this is not a question about job titles, it is a question about where a regulator can put a name.
First, Germany does not merely name the job, it names a person. The export officer has to sit on the body that legally represents the company, and is personally liable when the organisation fails. That is governance design, not hiring fashion.
Second, the EU already forces a named owner on the customs side. Trusted trader status is not granted without a person responsible for customs matters, demonstrable competence behind them, and written procedures. The role exists. It lives in an authorisation file rather than in a job advertisement.
Third, we run the same pattern in Singapore for strategic goods: nominate a control officer, then tell the authority when that officer changes.
So the jobs are not hiding, the accountability is. The question for your own board is whose name is on the file, and whether an internal audit could find it.
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