China: MOFCOM published new Guidelines on Internal Compliance Programs

On 28 April 2021, China’s Ministry of Commerce (MOFCOM) published The Guiding Opinions on the Establishment of an Internal Compliance Program for Export Control by Exporters of Dual-use Items. These Opinions come along with a 35-page Guidelines for Internal Compliance of Export Control of Dual-use Items.


The Opinions and Guidelines replace MOFCOM’s previous Opinions published in 2007 and are the latest steps taken by MOFCOM for the implementation of China’s Export Control Law effective on 1 December 2020. Chinese authorities see an effective export compliance program around 9 elements, amongst them a Management Manual.

Source: MOFCOM (28 Apr 2021)