The Netherlands Issues Guidelines on Internal Compliance Programs

Posted by Kelsay Calvaruso on 12/30/19 5:00 PM

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;
  • Training;
  • 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:

Topics: Compliance, Netherlands, Guidance

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