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ARTICLE · 31 JULY 2025

Internal Compliance Programs For Export Of Dual-Use Items: Key Insights From DGFT's Draft Framework

Lakshmikumaran & Sridharan
Lakshmikumaran & Sridharan
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Lakshmikumaran & Sridharan

Lakshmikumaran & Sridharan

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In our previous article, ‘Strengthening India's Export Controls: The Critical Role of Internal Compliance Programs', we examined the scope of SCOMET Law in India...

GlobalInternational Law

Background

In our previous article, 'Strengthening India's Export Controls: The Critical Role of Internal Compliance Programs', we examined the scope of SCOMET Law in India (dealing with export of dual use items) and touched upon what an Internal Compliance Program ('ICP') is and its significance in the export control framework.

Recently, the Directorate General of Foreign Trade ('DGFT') issued Trade Notice No. 07/2025-25 dated 14 July 2025 under Para 1.07A of the Foreign Trade Policy, 2023 ('FTP'). Through this Trade Notice, the DGFT has invited views, suggestions, comments, and feedback from stakeholders—including exporters, industry associations, and experts—on proposed amendments to the Draft Management System Requirements for ICP for Dual-Use Items, which are annexed to the notice.

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