The Ministry of Foreign Affairs in the Netherlands has published a guide for the implementation of an Internal Compliance Program (ICP). An ICP in this context relates to export controls, including sanctions and the export of strategic goods, anti-torture goods, and controlled technology. The guide emphasizes the Dutch Government’s expectation that an ICP is in place and followed by any organization that applies for or makes use of a Global Export License. The elements of the ICP include:
- Management commitment;
- Creating a compliance organization;
- Screening and pre-shipment controls;
- Training programs;
- Audits, reporting, and improvement measures;
- Record keeping.
This document, only available in Dutch, can be accessed through the following link:
