On December 6, 2019, the government of the Netherlands issued “Internal Compliance Programme: Guidelines for compiling an Internal Compliance Programme for Strategic Goods, Torture Goods, Technology and Sanctions.”
The guidelines cover the essential elements of an internal compliance program, which it defines as:
- Commitment to compliance with the legal requirements;
- Structure and responsibility for export control within the organization;
- Export screening procedures;
- Shipment controls;
- Audits and reporting; and
- Document retention.
The guidelines also provide more detail on the additional requirements for controlled technology, cyber surveillance, and potential torture goods.
The guidelines (in English) can be found here: