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ARTICLE · 29 AUGUST 2019

Sanctions Update: EU Commission Adopts Guidance On Dual-Use Internal Compliance Programs

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On July 30, 2019, the EU Commission issued guidance on internal compliance programs for dual-use trade controls.

European UnionInternational Law

On July 30, 2019, the EU Commission issued guidance on internal compliance programs for dual-use trade controls.1 The guidance consists of non-binding recommendations on seven "core elements" for an effective dual-use trade control internal compliance program. For each core element, the guidance sets out clear expectations for internal compliance, as well as the necessary steps for implementation. These are summarized in the table below.

Core Element What is expected? Steps involved
Top level management commitment to compliance
Written statement of support of internal compliance procedures:
  • It must indicate clear, strong and continuous engagement and support by top-level management.

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