On 9th October, the Steptoe International Compliance Blog published a post which explained that the EU had released draft guidance on the core elements that industry should take into account when implementing internal export controls and sanctions compliance programmes.  A public consultation until 15th November provides EU exporters the chance to comment on its core elements by completing an online survey.  Internal control programmes (ICP) are increasingly viewed in the EU as a key element for an effective export control system.  ICP guidelines have been introduced by some Member States as a tool to better monitor compliance with EU and national export controls.  The EU Dual Use Regulation Recast Proposal formally introduces standardised operational ICP as part of the assessment in the granting and control of global export authorisations and certain general export authorisations.  The article summarises the proposals and compares them to the US system.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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