Export Control: Internal Compliance Program (ICP)

An Internal Compliance Programme (ICP) describes the internal control measures required for monitoring compliance with export control legislation. It serves as an in-house manual detailing such matters as the internal protocols and procedures put in place to deal with all risks relating to export control.

An ICP is a customised document.

ICPs & global export licences

Usually, if you are applying for a global export licence, countries may require the exporter to have an ICP. Traditionally, there is no ICP requirement for individual and general export licences. In assessing licence applications, export control authorities determine whether a company’s ICP meets the countries' requirements.

The ICP requirement is, in principle, part of a countries' export control policy. The US and a number of EU countries have an ICP requirement for certain licence applications. There have been developments within the EU which could lead to ICPs becoming mandatory in all cases at some point in the future. An upcoming review of the Dual-Use Regulation may entail the introduction of EU-wide legislation requiring an ICP.

ICP format

There is no standard format for ICPs. Instead, the governments may require that a number of basic elements are included in every ICP. For specifics, guidelines have been produced.

The example of the Netherlands

The guidelines on ICP of the Netherlands 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.

See: guidelines on setting up an internal compliance programme for Strategic and Torture Goods, Technology and Sanctions.

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