Internal Compliance Program… - Trade glossary - The Trade Hub
Sanctions and Export Controlsen
Internal Compliance Program (ICP / PCI)
An internal system established by a company to ensure compliance with export control and sanctions regulations.
Internal Compliance Program (ICP / PCI)
An internal compliance program (Internal Compliance Program — ICP, or PCI in French) is an organizational system put in place by a company to guarantee compliance with export control, sanctions and customs regulations.
Key elements of a KPI
Management commitment: letter of commitment, appointment of a compliance manager
Risk analysis: mapping of products, markets and partners at risk
Screening procedures: systematic screening of customers, suppliers and destinations against sanctions and control lists
Product classification: identification of goods subject to control (dual-use, military, sanctions)
Training: regular awareness raising of the personnel concerned
Internal audit: periodic verification of the effectiveness of the program
Management of non-conformities: reporting and corrective action procedures
Recommendation from the European Commission
Recommendation (EU) 2019/1318 provides a reference framework for KPIs on dual-use goods.
Advantages
A strong KPI is a positive criterion for obtaining export licenses and AEO status. It constitutes a mitigating factor in the event of an unintentional violation.
Growing obligation
With EUDR, MACF, CS3D and the forced labor regulation, compliance programs must now integrate ESG dimensions in addition to sanctions and export controls.