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):
- Top-level management commitment to compliance;
- Organization structure, responsibilities and resources;
- Training and awareness raising;
- Transaction screening process and procedures;
- Performance review, audits, reporting and corrective actions;
- Recordkeeping and documentation;
- 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:
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1565015135434&uri=CELEX:32019H1318
