Internal Compliance Programme (ICP)

Last update 10.03.2023

While updating a new version of the OCEIT guidelines for establishing an internal compliance programme (ICP) in export controls for national economic operators, OCEIT advises them to refer to the recommendations of the European Commission for establishing or updating the ICP, namely:

For economic operators

The internal compliance programme (ICP) is 'a guidance which provides a framework to help exporters identify, manage and mitigate risks associated with dual use trade controls and to ensure compliance with the relevant EU and national laws and regulations'.

Commission Recommendation (EU) 2019/1318 of 30 July 2019 on internal compliance programmes for dual-use trade controls under Council Regulation (EC) No 428/2009

For universities and research centres

The EU recommendation 'provides a framework to help research organisations and researchers, research managers and compliance staff to identify, manage and mitigate risks associated with dual-use export controls and to facilitate compliance with the relevant EU and national laws and regulations.'

Commission Recommendation (EU) 2021/1700 of 15 September 2021 on internal compliance programmes for controls of research involving dual-use items under Regulation (EU) 2021/821 of the European Parliament and of the Council setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items

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