APAC export controls: How to get an ICP off the ground
Tangible tips

APAC export controls: How to get an ICP off the ground

Internal compliance programs are key for business growth in Asia Pacific. But getting started is easier said than done. Here are some useful pointers for you.

Author: Sebastian Zilm
Sebastian Zilm
18.03.2025

Internal compliance program: From theory to practice
Focus areas of your individual risk assessment
Risk assessment done – what now? Next steps.
Helpful ICP tools for APAC trade compliance managers

Internal compliance program: From theory to practice

In my first article on this topic, I’ve introduced the relevance, basics, and official guidelines for an ICP in the APAC region. If you’ve missed it, you can find it here:

APAC export controls 101: Internal Compliance Programs (ICP)

Today, I would like to share a few tangible pointers for establishing an ICP in your organization. The first key lesson to learn is this: There is no one-size-fits-all template. Please refer to my first article to understand key components and recommendations from your local jurisdiction.

And when you are ready to start – either from scratch or to optimize your existing framework – take a step back to put it all in the context of your own organization. Because the size of your company, your organizational set-up, the scope of your supply chain, and types of products you deal with are all crucial points to consider. To get to the bottom of this, you should naturally start with a risk assessment to identify the scope of your own, individual ICP.

I hope the following section delivers some useful tips to kick off your work.

Focus areas of your individual risk assessment

An export control risk assessment typically starts with four questions. Trade compliance managers are well familiar with them. An important point to keep in mind is that an export control risk assessment is not a one-time effort. It should be repeated as your business grows, your portfolio expands, and your supply chain adapts. And once your ICP is established, changes in applicable regulations must also be monitored to ensure your compliance measures always align with latest legal provisions.

Risk assessment done – what now? Next steps.

If all the above detailed risk assessment questions return non-critical results, you can keep your ICP slim. But constant vigilance is of the essence: Your business network, and portfolio is subject to changes. And regulatory requirements are never at a standstill either. If and as your environment changes, you need to repeat your risk assessments accordingly.

The screening of business partners against applicable sanctions and restricted party lists should always be firmly anchored in your Internal Compliance Program (even if questions 2-4 repeatedly return non-critical results). Using specialized tools is highly recommended – to ensure screening against latest applicable denied party lists and to avoid missing checks of business partner screening in any relevant business transaction.

Your risk assessment will also reveal which units of your organization should be involved in export controls. Companies often wrongly assume that it’s only a task for export or trade compliance teams. Teams such as sales, purchasing, product development, and support often manage crucial touchpoints with new customers, suppliers, or materials and are therefore essential to be considered and involved.

Once your risk assessment is complete and your status quo is determined, you need to put things in writing. This includes the details of your findings as well as specific measures you are taking to address each risk and meet your regulatory obligations. Involved parties and applicable tools and processes should be clearly defined – and this is what constitutes your ICP.

The final step: Awareness for trade compliance must be raised in all involved teams and organizational measures under your ICP need to be rolled out – and continuously trained – across all relevant units of your organization. Everyone needs to know what their role is, which processes apply to them, and whom to ask in case of uncertainties. Organizational charts may be helpful to visualize this and support the process.

Helpful ICP tools for APAC trade compliance managers

If your organization has a dedicated trade compliance or export control manager, you’ve already achieved an important milestone. In the APAC region – even more than in other regions around the world such as Europe or North America – trade compliance has traditionally been an area that did not get sufficient attention (and resources) from company management. But the ever more volatile geopolitical environment and increasingly stringent enforcement measures by export control authorities, have been fuelling a great shift in priorities for C-level executives over the last decade.

As efficient trade compliance management is gaining importance, more resources are made available to this important task that safeguards your business and forms the foundations for long-term success. When it comes to implementing trade compliance processes, however, there is still a lot of catching up to do in the APAC region. Simply adding more hands to complete the varied tasks involved is neither efficient nor effective. The volume of regulations to comply with and the number of data records to check is simply too high to manage manual sanctions and export control checks.

Scalable, flexible, and affordable cloud solutions are available to efficiently and securely support your processes in line with your company’s requirements. These solutions are not only easy to implement and straightforward to use but also provide complete logs of all trade compliance checks and keep you ready for internal and external audits:

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