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EU Issues Guidance on Internal Compliance Programs for Dual-Use Trade Controls

By Guy Soussan, Stefan Tsakanakis & Jack Hayes on November 6, 2019
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The European Commission recently published a non-binding Guidance with recommendations on internal compliance programs for dual-use trade controls under the EU Dual-Use Regulation. The Guidance aims to provide a framework to help exporters identify, manage and mitigate risks associated with dual-use trade controls and to ensure compliance with the relevant EU and national laws and regulations.

For more information on the EU Guidance on internal compliance programs for dual-use trade controls, see our advisory.

 

Photo of Guy Soussan Guy Soussan

Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures.

Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures. He also provides advice and assistance with EU economic sanctions targeting specific countries such as Iran, Libya, Syria, and most recently, Ukraine and Russia. His experience covers a wide range of industries, including manufacturing, energy, telecommunications, banking and insurance, petroleum and petro-chemicals, aerospace, and defense. He has conducted internal compliance audits, provided assistance on company compliance programs, and counseled clients on the application of the rules to specific transactions.

Read Guy’s full bio.

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Photo of Jack Hayes Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and…

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

Read Jack’s full bio.

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  • Posted in:
    Government and Public Policy
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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