European Commission Publishes Recommendations on Internal Compliance Programs for Dual-Use Trade Controls

Posted by Matt Schmitt on 8/14/19 5:00 PM

On July 30, 2019, the European Commission (EC) published guidance that provides a framework to identify and manage dual-use trade controls' impact and mitigate associated risks.

The guidance focuses on the seven core elements for an effective Internal Compliance Program (ICP):

  1. Top-level management commitment to compliance;
  2. Organization structure, responsibilities and resources;
  3. Training and awareness raising;
  4. Transaction screening process and procedures;
  5. Performance review, audits, reporting and corrective actions;
  6. Recordkeeping and documentation;
  7. Physical and information security.

The EC advises that the guidance provides a framework and should be non-binding.


The EC guidance may be found here:

Topics: Guidance, European Union

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