European Commission Issues Compliance Guide for Dual-Use Controls

The European Commission released a compliance guide for dual-use trade controls that details “common approaches” to compliance programs and lays out a “framework” to help exporters minimize risks, the commission said in an Aug. 5 notice. The guide outlines seven “core elements” that are “cornerstones for a company’s tailor made” internal compliance program: top-level management commitment to compliance; organizational structure responsibilities and resources; training and awareness raising; transaction screening processes and procedures; performance, review audits, reporting and corrective actions; recordkeeping and documentation; and physical and information security. For each element, the guide contains a “What is expected?” section and “What are the steps involved?” section to help companies assess their own programs. The guide emphasizes that the “most important aspect” of developing compliance programs is ensuring they’re “relevant to the company's organisation and activities,” easy to follow and “capture the day-to-day operations and procedures.”