Export Controls Internal Compliance Programme (ICP)

Authorities in several jurisdictions publish guidance describing what a good programme contains. It typically begins with a written commitment from senior management and a named person responsible. A risk assessment identifies products, markets and customers that carry export risk. Procedures cover how items are classified, how customers and end users are screened, when licences are needed and how orders are blocked or released. Staff in sales, engineering, logistics and IT are trained to spot red flags. Records are kept, internal reviews are carried out, and problems are reported and corrected. Some licensing systems grant simplified procedures to firms with an approved programme. The programme is meant to catch mistakes before shipment. Enforcement authorities ask to see the programme first, and what they find there can move a penalty up or down.

A manufacturer of precision instruments sets up a programme after expanding into new markets. It appoints an export compliance manager, classifies all 300 products and builds an order system that stops any sale to a flagged destination until approval is recorded. Sales staff receive annual training, and a yearly internal review samples shipments to confirm the checks were done.