SEESAC Publication: Internal Compliance Programmes

A central element of any national export control strategy is to ensure that entities involved in the trade of controlled goods are both able and willing to carry out their activities in accordance with national export control legislation. With this in mind, many governments seek to enshrine an ‘export control culture’ among the relevant companies. One of the important ways in which this is accomplished is through government support of company internal compliance systems, or ICPs. In the following report, "Internal Compliance Programmes," SEESAC research team provides an overview various existing ICP requirements in four countries and one company. Using these examples, the report explores the role of the key aspects of a successful internal compliance system, namely:

1. A commitment from senior managment to comply with national export controls;
2. The designation of a senior member of the company as head of the ICP to ensure implementation of the ICP.
3. A regularly undated written guide detailing compnay compliance policies and procedures, possibly in the form of a software package.
4. Ongoing training of staff dealing with different aspects of processing exports.
5. The screening of all aspects of an export (products, customer and end-user; destination; end-use).
6. Adherence to national export control legistlation record-keeping requirments.
7. Establishment of procedures for regular internal audits and compliance monitoring within companies.
8. Establishment of procedures for handling and resolving compliance problems and violations.

The production of the regional report was made possible through the generous support of Norway.

The report is available in both English and BCMS.