Suzanne Bullit - Senior Director of Trade, Nike
In this episode, Suzanne summarizes research she conducted while getting her masters degree from Loyola University. Suzanne recently completed a Master of jurisprudence in enterprise risk management and shares the results of her thesis research on the effects of export sanctions requirements on exporters as well as best practices for companies setting up an export compliance program. She shares her career advice for up and coming professionals and best practices for setting up a mentoring relationship.
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Full episode transcript:
Introduction (00:01):
Welcome to Women in Trade, a podcast for up and coming professionals like you in the field of international trade. Kellie Kemock is your guide on this journey, an accomplished lawyer and trade compliance consultant who's passionate about helping young women navigate this complex field, equipping you with the tools and resources you'll need to pursue an exciting and meaningful career. You'll hear candid interviews with other successful female leaders and benefit from their experience. It's time to build the career of your dreams. Here's your host, Kellie Kemock.
Kellie Kemock (00:42):
Today's episode we have Suzanne Bullit, the senior director of trade at Nike. I know it's a long story probably, but maybe if you can give us the cliff notes of your career.
Suzanne Bullit (00:55):
Sure. So where I am now, so I am the senior director of Trade and Customs for Nike Inc. Out of Portland. Great company to work for a really exciting opportunity to be here and I've been at Nike for a little over a year, but I started my trade journey, I wanna say it was over 25 years ago at this point. And I started working on the brokerage side. So I was an export account manager at a forwarding agency and well known forward outta Boston and started there back in the nineties. So I was typing up export declarations and airway bills on a typewriter at the time, which was kind of fun to think about and see how far we've come from a technology standpoint, from a trade lens. But yeah, started there and quickly migrated over to the corporate side after working for a forwarder.
(01:46):
And I've been on the corporate side ever since. And to your point, I've worked for a number of different industries in the past. Everything from on the industrial manufacturing side, like the oil and gas industry, nuclear power chemical industry. And I've also worked in retail as well. So I've worked for Walmart as well as Nike on the retail side. And every industry has their different flare and how they handle trade and customs compliance and what the focuses are and the way you structure your programs. So it's been a long journey, it's been a lot of fun and I really enjoy where I am right now.
Kellie Kemock (02:21):
Great. And you recently completed a master of laws at Loyola, is that correct? Can you tell us a little bit about that?
Suzanne Bullit (02:30):
Of course. It's a master of jurisprudence, which is a master of law at Loyola University in Chicago. So they've got great masters programs that really focus on the business law side that has a concentration in compliance especially corporate compliance, not as much on the trade side, but more on the corporate side. So it hones in on F CPA regulations, how to set up a corporate compliance structure, everything from policies and procedures to risk assessments and how you set it up for audits. So it really hones in on that business law with the compliance focus side. And I was really attracted to that. I looked at a number of different schools and it really liked Loyola's program on the way it was structured and signed up for that and completed it. Their program now if folks are looking into it, is called a master of jurisprudence in enterprise risk management. So I can recommend that when I started it was the business law with a compliance concentration. But again, a great program, not only if you're working in corporate compliance, but also for health law compliance. Really great program. I couldn't recommend it more.
Kellie Kemock (03:45):
How would you describe the overlap between corporate compliance and global trade and trade compliance?
Suzanne Bullit (03:52):
I think it really depends on the company that you work for where you see the overlap. So most companies, trade compliance is often held separately than on the corporate compliance side. So you see corporate compliance being sort of your overarching structure on everything from code of conduct training on harassment and other sort of overarching compliance matters. But trade compliance is kind of off to the side. Sometimes I say that we're almost like the black sheep, they don't know where we fit. Are we in supply chain? Are we in finance or tax? Maybe are we under legal? And there's no right way to do it. Every company does it a little bit differently. And I've been on both the legal side and in supply chain in trade compliance. And it's really just where does it fit best within the organization for the best focused. But what I love about trade compliance is the overlap mostly on the know your customer side and know who your transaction business with.
(04:54):
That's where I find most of the overlap is that in doing sanctions compliance and due diligence on parties and especially on the export licensing, you really wanna know who your customers are and that can directly connect with the corporate compliance side with third party due diligence with assessing your vendors and your suppliers and who you're doing business with. So it really can make that connection all into one. And I really enjoy that aspect about where I was sitting at the time, which is why I enrolled in the MJ program at Loyola. Cause I was overlapping with corporate compliance a lot. I often saw myself kind of diving into UK Bribery Act areas of interest in f CPA law concerns. And so I saw the direct connection and said, this is a great connection for me to make and I can see trade compliance kind of migrating in that direction, again based on the industry that you're in and the company that you're with. But it really does have a direct connect.
Kellie Kemock (05:53):
And I've been asked a couple times whether having a law degree helps you in the trade space. And I'd like to ask you the same question as to whether, how much does a law degree help you in a trade compliance field? And it seems like it would help you in a corporate compliance field, but what is your opinion on that?
Suzanne Bullit (06:14):
Yeah, I think again, I think it depends where you're seated within your organization. So if you're seated on the supply chain side, maybe not as much because the focus may not be as much on the legal side of what you're doing from a trade compliance perspective. But if you're seated in legal, then definitely I find that I think it would be really helpful. Not only does it put you sort at a level playing field with your colleagues, cause most of your colleagues will likely have a law degree in terms of being part of the corporate attorney staff or part of maybe S E C compliance or other functions within legal for that organization. But I think it really helps on the legal side for the assessments of the things that we talked about is understanding all the trade laws and regulations and then how you take those and apply them to the business.
(07:03):
It's really that breaking down of all those laws and regulations and what needs to be done for your business and then how do you turn those into best practices. So I think from that aspect it can be really helpful because it gives you that sort of legal insight that maybe you wouldn't have if you did not have a law degree. Do I think it's necessary? Absolutely not. There are many, many successful people in trading customs who have done this for years and years and who've been wildly successful without a law degree. Do I think it's helpful maybe for some industries and for the way trade is heading? Definitely. And for me it was a personal choice. It wasn't one that I felt pressured into going into, but I thought it would only not only enhance my career, but just enhance my knowledge in general.
Kellie Kemock (07:49):
It seems like a lot of your career has been focused on the export side. Is that true?
Suzanne Bullit (07:53):
Yeah, I actually grew up on the export side. I always say that, so you're right. I came up on the export side have focused a lot on the export side. I'm obviously very well versed on the import side as well, but export is kind of my forte. It's where I started and it's kind of where my heart is at. So I love everything to do with the export side, export declarations, export controls, sanctions, regulations. So it's really where my passion lies and I find it to be a lot of fun. It's also a lot of fun cuz it changes all the time. Import regulations they change as well. But I find the export side to be, especially in a current geopolitical conditions, quite volatile these days and they're changing on a day to day basis of time. So it makes it fun and interesting and challenging as well to keep up with those regulations and then migrate those into your best practices.
Kellie Kemock (08:46):
Does someone who's starting their career, do they have to decide whether they enjoy import or export or do you think that they can kind of navigate a career in between both sides of
Suzanne Bullit (08:58):
Both sides? Yeah, I, well I think that's the way the industry has been headed the last few years. So I mean, when I started 20 years ago, I think there was the two tracks of work, you almost saw someone really focused on the export side and individuals on the import side. And even in corporate structures, it was two teams at times that were managing, one was managing export and one was managing import. It wasn't until maybe 10 or so years ago that they kind of merged them under that overarching trade compliance umbrella. And so now if you are starting off in your career, and I don't think you need to make a choice, I think there's opportunity to learn both sides. And there's a lot of similarities between both. I mean there's definitely nuances, but there's similarities. And again, if you're following both tracks of work, I think it makes you really well rounded and a attractive employee and also an employee that shows initiative and ambition to move on in your career and learn more as you go.
Kellie Kemock (09:57):
That's why I find this field so interesting. There's always something to learn,
Suzanne Bullit (10:01):
Always. Definitely <laugh>.
Kellie Kemock (10:03):
Well, speaking of something to learn in your master's program one of the requirements was to write a thesis. Can you tell us a little bit about this thesis and what it took? How did you do your research? And then maybe you can give us a summary of it.
Suzanne Bullit (10:22):
Yeah, sure. So when I was deciding on a thesis topic I was kind of thinking about where does my passion lie and what would I wanna spend hours and hours and hours on and researching and writing on. And as you mentioned, the export control side is really where my passions lie. And I love sanctions compliance and find that they're often changing so quickly. There are so many different entities that have a say from an administrative standpoint and sanctions compliance. And having worked in the industry for so long, I find it sanctions compliance is one that's always often difficult for the business side to manage because there are so many moving pieces in parts. The regulations are not crafted in a way where it's a check to box of everything that you need to do. You often have to read between the lines. I mean it's really like you got a deep dive into that.
(11:17):
And so when you're writing a sanctioned compliance program, it's difficult. So in choosing my thesis topic, I was kind of thinking about, well, how do I take all of that and put it together into something that's relevant? And I started looking at academic journals and other sort of economic journals as well that would tailor towards sanctions compliance. And the only thing I was really finding was how do sanctions impact the body that they're targeted toward? How do they impact the country? How do they impact the entity that they're targeted towards rather than the industries that are left to manage them, which is the business is primarily from a US perspective. It's US organizations, US persons, in the case of OFAC that have to manage the sanctions compliance requirements. And while the sanctions are not targeted at you as an exporter, you're the one that has to manage all of them and put together your sanctions compliance program.
(12:16):
And by the way, if you violate them, you are the one that's in trouble, not the targeted body. So there wasn't a lot of academic journals about this. Everyone really wrote about the impact on the target. Did they change their policy, did they change their practice? Did they change their geopolitical intention? But no one was really writing about the burden on the US exporter to not only stand up the program but manage the compliance efforts and also the risk that they would incur if they didn't manage them well. So I couldn't find a lot of academia about it. So that's what I took on is really looking at sanctions compliance from the perspective of the US party rather than the government perspective or the economic perspective of the targeted impact.
Kellie Kemock (13:05):
It seems like most people were looking at the intended consequences of sanctions regulations, and you were kind of looking on the other side, like the unintended consequences almost.
Suzanne Bullit (13:16):
Exactly. Yeah. It's the unintended consequences behind the scenes that the US exporter needs to manage in order to maintain compliance with US sanctions. And as I mentioned, right, there's a num number of different agencies that have sanctions on parties outside of the United States and even inside the us. So I honed in primarily on Department of Treasury sanctions under the Office of Foreign Asset Control. And as I mentioned, OFAC doesn't give you, or up until recently, they didn't give you many guidelines. So as a sanctions compliance professional, mostly a trade compliance professional, your job was to kind of read through all the OFAC regulations, including all their citations, all the violations, and determine, okay, well this is what OFAC is saying, so this is what I need to implement. There was a lot of reading between the lines to understand what OFAC guidance was to us exporters up until 2019, they really had no formal guidance.
(14:12):
They recently issued it, and if you read that, it reads more as a directive than a guiding document. But I thought it was really interesting to kind of look at the history from the last five years of the way OFAC constructed their guidance and then how that US exporter was headed to put it all together and then really what it meant for the US exporter. And not only did I look at it from a standing up a sanctions compliance program and that framework, but I also looked inherently at jobs, wages impacted corporate revenues to maybe pull out of different countries when sanctions were implemented, stopped transactions with certain foreign customers if they had big, big projects or programs that they had stood up. So really kind of looking at the burden overall from an economic standpoint as well as a corporate compliance standpoint.
Kellie Kemock (15:05):
Wow. And what did you find, What was the unintended consequence and the burden? Did you evaluate it? Did you say was it worth it or not? That kind of thing?
Suzanne Bullit (15:15):
I did. So my thesis argued that most of the sanctions, I really honed in on Russia from a sanctioned perspective, that most of the sanctions had very little geopolitical impact on the targeted entity. And that instead they had significant impact on the US exporter and the US person who was required to manage those sanctions. So that was the initial argument of my thesis and then kind of proved it throughout the course of the document. But yeah, I would say it was a strong argument at the end that, and I don't wanna turn this into a geopolitical podcast, but the basic argument was that the US sanctions on Russia had very little impact on the Russian cost of action. And instead had all these burdens on the exporter, again, standing up their program the level of investment they needed to make in terms of subject matter expertise, resources, audits, self-assessments, sufficient screening programs that needed to be in place.
(16:18):
And screening programs that were sufficient are not just about having a screening provider that integrates with your E R P system. It's a screening provider that picks up acronyms in your company names at your screening against, screening against addresses, it's screening against your ofac 50% ownership rule mean how do you manage all of these things and put it all together so it creates that sanction compliance program that OFAC is demanding. And when you add it all up, it was pretty significant. And again, the burden was really on the US exporter side, but I was arguing that from a geopolitical positioning side that not much was changing, but you saw the US exporter bearing all the burden of the changes.
Kellie Kemock (17:02):
Do you have an opinion on whether that burden is different, whether they're a multinational corporation versus small medium size companies?
Suzanne Bullit (17:12):
I think it depends. Again, it depends on the industry and how you conduct your business. So if you're doing business in emerging markets or markets that are subject to heavy sanctions either country specific sanctions or sanctions on certain types of entities or types of industries, then it becomes more complex. So I found that the complexity line lies on the industry side, not as much on whether you are a large multinational or a small multinational, but just how you conducted your business, who you conduct your business with, the entities you were conducting your business with, and maybe the types of projects or programs or even products you are selling.
Kellie Kemock (17:54):
Are there any solutions? Is there a better way to manage policy around sanctions in order to not have so much a burden?
Suzanne Bullit (18:04):
I think what needs to happen is there probably needs to be more research done. And again, not just from an academia standpoint, but from an economic standpoint and from a political standpoint to see what the sanctions impact truly are before we continue on this course of action to keep layering on sanctions upon sanctions and having no geopolitical change. I mean, if you try to look for sanctions research, there's a lot from the nineties, but there's not a lot for recent sanctions activity and whether changing geopolitical intention. So I think there needs to be a lot more of that done to prove whether sanctions are getting us what we want or if they're just again, creating that burden on the exporter and also creating that sort of political hurdle and distrust between countries.
Kellie Kemock (18:53):
And I guess the flip side of that question would be how can we make it easier on the exporter? How can policy and the enforcement change just a little bit to make it a little easier to comply?
Suzanne Bullit (19:08):
Well, I think OFAC kind of started heading in the right direction in 2019 with their framework for their sanctions compliance program and their advice and guidance that was given, Again, it's called a guiding document, but it reads more like a directive, I believe. And I think that's a great start for ofac and maybe it's just a start, but I think that should be enhanced upon because that document now really gives a sanctioned compliance professional that methodology that you can read between the lines of the guiding document on what you need to do in order to have a sufficient compliance program where you've got all the boxes checked. But I think that's the real start. It's for OFAC to kind of take all their underlying guidance, not only in the way their sanctions were crafted, but in again, some of their violations, some of the citations that they've made. Pulling that all out and putting it into that framework for a USC border is certainly helpful and it's gonna help mitigate further violation. I also think if you kind of flip that over to the technology side, is getting our technical counterparts up to speed on software screenings and solutions and other systems and capabilities that can help manage OFAC sanctions and other sanctions requirements, whether they be product specific or industry specific. If we can start upping those technical capabilities, that'll really take some of the burden off the day to day work.
Kellie Kemock (20:37):
Definitely. That was gonna be my next question about automation and how machine learning and all of these automation software providers that are coming up, can that actually help with this sanctions compliance?
Suzanne Bullit (20:52):
Yeah, so I mean from an automation perspective, they're actually encouraging it now. And even before the 2019 framework guidance came out, they started saying that not only did US exporters have to have a screening solution, but then they started adding on that it needed to be more robust and more comprehensive. Were accounted for acronyms in company name. I think now with the OFAC 50% rule, you almost have to have a very robust screening solution from a technical standpoint to manage that 50% rule if or have reason to know that you are selling to entities or maybe conducting business with entities that may be subject to those 50% laws whether it be in certain markets or certain countries or certain types of industries, it's almost mandated. So you've gotta have that 50% identification software in place to comply. So again, they're telling you now to have those robust systems in place.
(21:55):
They're not telling you which systems to have in place or how robust they need to be. They're just saying they have to be robust and that you need to have a system in place for screening. I think to your point though, can we use other types of automation? Can you manage some of the sanctions compliance? Sure, why not? So if there's a lot of sanctions, for example, on oil and gas industry, then I don't see why there can't be robust solutions developed to sort identify products that may be utilized for certain applications that may trigger a sanction activity, why a software couldn't be written to help identify those. And again, that takes the burden off your sanctions compliance professionals from having to review every single transaction that may be in violation and really kind of hones them in on those that would be high risk.
Kellie Kemock (22:45):
Yeah, it almost seems like it is not possible to operate an export compliance program without a system. It doesn't seem feasible to do it manually.
Suzanne Bullit (22:57):
No, it's not recommended. Definitely. So I can see maybe small companies that do very small number of transactions going that route. But again, any time, even in any compliance program, whether it be sanctions or otherwise, every time you have manual processes, you open yourself up to more risk. So the more we can add automation in to help those processes, the better we are from a risk position.
Kellie Kemock (23:20):
And then just to tie in your career history, will you talk to us about the different industries that you worked in and maybe how export compliance or sections compliance, it looks different in each of those industries?
Suzanne Bullit (23:36):
So I would say from, well, from export control standpoint, I mean certain industries clearly have products that are subject to an export license and others do not. Mostly in consumer goods, you're not gonna get a license most of the time, whether it be food products or apparel or footwear that's not gonna happen. They flow pretty freely. Whereas other industries, export controls are a lot more robust. You've got products that are subject to regular license requirements that may be a bis department of commerce license. You've also worked in the nuclear industry as well, and you could be subject to NRC licenses or even on the chemical side, my DEA license as well. So you've gotta be familiar with all those entities again, in the industries that you're working in to understand what export controls are in place and then what compliance programs are needed.
Kellie Kemock (24:29):
So from a career planning perspective, it sounds like for those who might be interested in export controls, they definitely would want to look for employment in a particular industry that focuses more heavily on export controls. So from a career perspective, you know, can plan that out by choosing the correct industry for the expertise you wanna build.
Suzanne Bullit (24:55):
Yeah, I would agree with that. I would say if you've got a certain interest and a certain type of, whether it be import or export, if you were looking for really being an export control industry professional, and yeah, you'd obviously wanna get experience in an industry or at types of companies that have products that are subject to more export controls where you have opportunities to apply for licenses and work with the different licensing agencies, that would give you more perspective, more industry experience on that side. And again, you can also look at the type of company that you work for too. Are you working in the United States, for example, for a heavy US exporter, or are you working for a heavy US importer? So I would say don't just view it from a industry standpoint. It's also the company that you're working for looking at their import export portfolio and understand and not cause then you can see where the complexities will lie and what type of exposure you're gonna get and experience you're gonna get.
Kellie Kemock (25:53):
Do you think that someone can ask that in an interview? Can they ask, are you majorly an importer or majorly an export? Can they ask those kinds of questions in the interview or what would you suggest?
Suzanne Bullit (26:03):
Yeah, I mean I would suggest I always do your homework before you go into the interview. So kind of do research on the company. You should be able to find, they have statistics in the Journal of Commerce on the export side and the import side that you can find. So you can see what their import and export portfolio looks like. I normally would recommend that first, but I don't see why it would be a problem to ask that as a question, especially when you're asking about the roles and responsibilities, where your focus would be and what am I gonna be working on the most or how does the company handle export or how does the company handle import or what types of volumes are you seeing? Is this the trend for the way the company is going? Anytime you show interest in the company that you are interviewing with, I think it's to win all the way. And especially if you show up doing your homework and then you ask them questions about the company, I think it shows real interest not only in the job that you would take, but in the industry you'd be working in and in the company you'd be working for.
Kellie Kemock (26:57):
On the podcast, I like to talk about mentoring because it's something that people contact me about. And so I always ask for advice on how can I provide better mentoring advice. But also if you can imagine listeners to the podcast being newbies in the industry, what kind of advice would you have for them?
Suzanne Bullit (27:19):
Yeah, sure, I can do mentoring questions. That's probably the most fun of what I do. In fact, the last two days I've answered questions from two prior employees about how would I handle this situation, how do you handle this situation? So it's a lot of fun for me. Yeah.
Kellie Kemock (27:34):
Well, okay. So in your view, or how do you set up a mentoring relationship? I mean it, it's such a specific term, but yet it can mean so many different things depending on where you are, where your mentee is and their careers and what questions they have. So what's your opinion on the mentoring relationship, how to set one up and how to make it as useful as possible?
Suzanne Bullit (27:57):
So I really think it depends on the mentee and the mentor cause it's really making that one on one-on-one connection. So I generally leave it up to my mentees to determine how the relationship is gonna go. Do you want to meet with me on a regular basis, schedule something in the calendar, it's on a fixed day at a fixed time and we show up for coffee or we used to show up for coffee, now we show up on Zoom. But do you wanna do it that way where you have your questions ready and you've been compiling them all month or is it more of a one off where you're gonna text me and be like, Hey Suzanne, I ran into this in my role, what do I do? Or how would you approach this? Or do you think my approach is right or what should I change?
(28:41):
Or my boss said this to me, am I reading too much into it? I guess it really depends on the mentee and I've get all different facets from very structured to very loose with the text message. I'm good either way, but I think in the very beginning it's nice if you wanna set up a formal relationship and you don't know the mentor very well, ask them for something a little more formalized on a regular basis until you kind of develop a rapport with them and you've got a personal relationship. And then you can easily switch to the text message very quickly.
Kellie Kemock (29:12):
And the one rule that I live by, and maybe you can gimme your input on it, but the one rule I live by is you shouldn't be asking your mentor for a job. What do you think of that?
Suzanne Bullit (29:25):
I don't think I've ever had anybody come right out and ask me for a job. What I've heard instead is, Suzanne, I'd love to work for you again, <laugh>. So I mean they kind of throw it out there. And of course most of my mentees, I know all of their pros and their cons, so I know all their strength and all their opportunities do. So if something were to come off, I would have the opportunity to contact them and say, Hey, I think this would be something that would be great for you. I'd find that it probably works better. Just that with the mentor mentee relationship, maybe outside do the reporting line and sometimes even outside of maybe trade. So if you're looking at having a mentor or looking at a mentor, maybe don't say, I only have to have somebody who's been in trade compliance for 20 years. Maybe look at someone who's been in legal or in corporate compliance or who's high up the chain in supply chain. Right? <affirmative>, we've kind of navigated the waters and especially if they're in your own organization, I find that the mentor mentee relationship is better if it's outside, definitely outside even sort the broader reporting line. And that way you're, you're getting guidance but it's not impacting the overall relationship in the company too.
Kellie Kemock (30:36):
I make these hard and fast rules for myself and then my podcast guests just like, Nope, that's not a good rule. One of the rules was I would never work for a company where trade compliance didn't report through legal. And that was just my personal opinion because I have a law degree. I think I'm realizing now that because I have a law degree that makes sense for me where I see more mobility in a company that has a trade compliance in the legal department, I have to stop having these hard and fast rules is what I'm learning.
Suzanne Bullit (31:06):
<laugh>, I think it really depends on where you wanna go. I mean, I think with every individual you may enjoy one versus the other who you report up to but it doesn't make them wrong or it's just what's different for the individual. I've worked for both supply chain and for legal and I enjoy both. They have a very different spin on them at times. And while we're always a compliance function, it definitely can have a different focus. And so it can often be very different working for one versus the other. I'll say in the past working for legal, when I bring up business cases or about return on investment, they're not used to hearing that stuff in the legal department. So they either don't quite know what to do with you or they're really excited about the business case that you've initiated and that you're proposing. Whereas when work for supply chain, that's a regular course of action and it's almost anticipated. So again, very different flares but doesn't make one right or wrong just where you feel more comfortable. And I don't know if necessarily know if it needs to be a hard and fast rule at all. So I think generally where your interest lies and where do you wanna go.
Kellie Kemock (32:23):
Thank you so much for your insight today. I definitely appreciate it and I thank you for your time. Thanks for listening to today's episode.