THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 80, June 2019

Internal compliance programmes: Industry as a responsible stakeholder in international trade

Though the use of ICPs is well established in the United States, in Europe debate continues as to whether they should be compulsory for exporters of dual-use products. But, writes Rosa Rosanelli, a..

Though the use of ICPs is well established in the United States, in Europe debate continues as to whether they should be compulsory for exporters of dual-use products. But, writes Rosa Rosanelli, a strong but flexible ICP can help both business – and government regulatory authorities – meet their aims.   Without active and consistent implementation from companies in the private sector, export control measures cannot succeed. Where they do so, companies can – through diligent screening, understanding of end-users, and the application of risk-mitigation strategies as part of their internal compliance programmes (‘ICPs’) – provide such value as to...

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