Updated: Dec 29, 2019
The EU has made a recommendation on internal compliance programmes for dual-use trade controls under Council Regulation (EC) No 428/2009
The EU has published a recommendation for a so-called ICP to create an effective, uniform and consistent system of export controls on dual-use items in the EU. As such, the EU believes that common approaches and practices as regards internal compliance programmes can contribute to a uniform and consistent application of controls throughout the EU.
And the EU has repeated that we at Customs Manager are always saying, that awareness and active efforts are needed to comply with trade restrictions, export controls and customs regulations. This is especially true in Export Controls where the rapid scientific and technological advancements and the complexity of today's supply chains create and ever bigger need to understand and carefully follow trade controls to a great extent.
It is, therefore, not uncommon that companies have put in place a set of internal policies and procedures, also known as an Internal Compliance Programme (ICP).
The guidance published by the EU Commission provides a framework to help exporters identify, manage and mitigate risks associated with dual use trade controls and to ensure compliance with the relevant EU and national laws and regulations.
It is not a new law, however several EU Member States consider it, in essence, necessary to demonstrate understanding and compliance with rules & regulations. Some have even tied use of EU or national General Export Authorizations to it.
ICPs have moved into more focus now and it is right for EU and globally operating exporters to consider adopting such programme or evaluating its effectiveness. We offer ad-hoc, bespoke SUPPORT to customs managers & global trade professionals in exporting companies to understand, evaluate, apply and implement ICPs in any business, large or small, wherever located in the world.