THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 83, October 2019

The proliferation of ICP standards: Theme and little variation (or, so what?)

Dr Scott Jones argues that while ICP standards are to be welcomed, in the absence of a globally-recognised certifying body or norms, their effectiveness is circumscribed.

Dr Scott Jones argues that while ICP standards are to be welcomed, in the absence of a globally-recognised certifying body or norms, their effectiveness is circumscribed.   Earlier this year, both OFAC and the Department of Justice serially published compliance guidelines, albeit with their respective administrative and criminal emphases.  Last month, the European Union issued its ‘Recommendation’ on internal compliance programmes (‘ICP’) for dual-use trade controls, the earlier versions of which appeared as drafts and working papers. These and related guidance documents, from the Bureau of Industry and Security (‘BIS’) and other government agencies, are increasingly converging on core elements...



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