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Internal export control compliance program

30.06.2011

An internal export control compliance program is an option for enterprises that wish to introduce fixed procedures in the enterprise for the purpose of ensuring that the export control rules are complied with. The advantage of an internal export control complicne program is, therefore, that the enterprise in a fairly simple manner will get a better grip on export controls, and that the enterprise at the same time ensures for itself a good reputation in the export control field. Furthermore, the internal export control compliance program may be combined with less administrative work in the form of just one general authorisation.

Basically, the internal exprot control compliance program comes in two versions:

  • Authorisation/ certification under the guidelines for the internal exprot control compliance program.
  • Authorisation/ certification combined with the acquisition of one authorisation covering all exports subject to export controls.

The reason why there are two versions is that not all enterprises have an interest in acquiring one general authorisation even if the enterprise in other ways will benefit greatly from being authorised according to the guidelines governing the internal export control compliance program.

This is due, in particular, to the fact that the internal exprot control compliance program is also very relevant for enterprises that exist on the border between export controls and ordinary exports, for the very purpose of ensuring that the enterprise always considers the export control rules to the necessary extent. It is therefore not a requirement but an option that one general authorisation is issued to enterprises that introduce an internal export control compliance program.

Authorisation under the guidelines governing the internal export control compliance program
A condition for being authorised under the Danish Enterprise and Construction Authority guidelines for internal export control compliance program is that the enterprise accepts an offer from the Danish Enterprise and Construction Authority to introduce an internal export control compliance program. Export control management is based on environmental management (ISO 14000) and quality management (ISO 9000), but is less resource demanding than these two systems.

In connection with the introduction of the system, the enterprise commits itself to, among other things:

  • Developing an export control policy.
  • Training staff.
  • Introducing procedures for export controls.
  • Staying updated on current legislation and
  • Performing internal audits.

Authorisation, combined with the acquisition of one general authorisation
Another advantage of introducing the internal export control compliacne program is that the Danish Enterprise and Construction Authority offers to tailor one general authorisation (comprising both general and global authorisations), which will reduce the application work. This will bring down the administrative work of the enterprise whose exports, to a high degree, are subject to export control rules. In exchange, the enterprise has to introduce a number of internal procedures to ensure current compliance with the export control rules.