The European Commission has published a recommendation for an internal compliance programme (ICP) for trade in dual-use items. The guidelines are not binding on businesses.

The EU and its Member States have strict regulations that need to be observed when trading in dual-use items. The European Commission has provided businesses with guidelines in Commission Recommendation (EU) 2019/1318 from July 30, 2019. We at the commercial law firm MTR Rechtsanwälte note that while the suggestions are not binding, businesses can treat them as a guide to internal compliance systems. The Recommendation also serves as guidance to customs authorities and Member States.

It essentially covers seven points, including top-level management’s commitment to compliance, performance reviews and corrective actions, and physical and information security. An internal compliance system must nonetheless always be tailored to a business’s structure, size, and business activities, as well as the risks involved, with risk assessment playing a particularly important role.

Lawyers experienced in business law can advise on setting up an effective compliance system or answer any questions you may have concerning export controls.  

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