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Internal Compliance Program - Series (2) - Do's and Don'ts when starting the ICP process

Today, in the second article in thehands-on practical advice series on Internal Compliance Programs for Export Control:

Part 2: Do's and Don'ts when starting the ICP process



  • do not envisage to copy-paste any other company's ICP

  • do not rely on third parties promising you to sell you ready-made ICPs (more on that topic in the next contribution)

  • do not think that you are able to draft and submit your ICP within two weeks

  • do not start on the basis that your ICP will be done without any internal ressources from your side (in particular, input and assistance from compliance team, product engineering, customer relations, sales department, management)

  • do not think that the ICP is a one shot (as it requires periodic updates and auditing)

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