Guidance
APAC export controls 101: Internal Compliance Programs (ICP)
Trade compliance is of increasing importance in the APAC region to ensure long-term business success. But what makes an effective ICP? What are official guidelines?
21.02.2025
Why do you need an ICP and what exactly is it?
There is no denying that implementing an effective trade compliance program (ICP) is a tall order. But for businesses in the APAC region, having a future-proof program in place to ensure sanctions and export control compliance is becoming ever more important to keep or gain a competitive edge and ensure long-term business success.
Customer, suppliers, stakeholders and investors are all looking for reputable and secure business partners in today’s highly dynamic global trade environment with ever-stricter regulations. No-one can afford compliance transgressions and the legal, financial, and reputational repercussions they involve.
In this article, we’re looking at the basics of an ICP to support companies in APAC in finding the right approach for their business. Internal compliance programs generally serve to support an organization’s adherence to legal regulations – in this context specifically regarding foreign trade.
As such, an ICP documents a company’s internal control measures for complying with relevant export control legislation. It serves as an in-house manual and includes internal protocols and standard operating procedures that must be observed to manage all risks relating to export controls.
Official ICP recommendations and guidelines vary by jurisdiction. It is therefore important to refer to the export control legislation applicable to the jurisdictions that apply to your company. An ICP may need to be in place when, for example, companies want to apply for certain types of export licenses. Outside of legal provisions in national foreign trade laws and export control regulations, a legal basis for ICP requirements may also be found in due diligence requirements of general company management.
Basic elements of an Internal Compliance Program
1. Management commitment
2. Training and awareness
3. Screening and checking transactions
4. Recordkeeping
5. Written policies
6. Self-audits
7. Change management
8. Software automation
Internal Compliance Program (ICP) guidelines
In general, there is no standard format for Internal Compliance Programs. The content of an ICP is typically customized and highly company-specific – tailored to the specific products and processes of an organization and the jurisdiction it is subject to.
Want to deep dive further and learn how to get started? Then take a look at my next article on the topic: APAC export controls: How to get an ICP off the ground
With regards to general criteria, various export control authorities across the globe have issued official guidelines around Internal Compliance Programs. In the following section, you can find some examples – by country, in alphabetical order.
Australia
European Union
Germany
Hongkong
Japan
Netherlands
Philippines
Singapore
Taiwan
United Kingdom
United States
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AEB's export control solutions deliver comprehensive security for your business with always available and up-to-date software for Compliance Screening, License Management, Export Controls, and Risk Assessment. In the cloud and integrated in systems such as SAP®, Salesforce, or Microsoft Dynamics 365.Similar content
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