An Export Internal Compliance Program (ICP) represents a set of corporate policies and procedures ensuring a company's compliance with export control legislation. In Georgia, implementing an ICP is becoming critical for companies involved in international trade, especially when dealing with military or dual-use products. An effective compliance program protects the company from inadvertent violations, sanctions, and reputational damage. State agencies (Ministry of Defense, Revenue Service) view the existence of an ICP as an indicator of a company's reliability, simplifying the permit acquisition process. Legal.ge offers a full service to create and implement an internal export control system in your company.
What does this service cover?
Our service covers all stages of ICP development and implementation:
- Risk Assessment: Auditing the company's export operations and identifying potential risks (products, partners, routes).
- Policy Creation: Writing an export compliance manual detailing decision-making procedures.
- Employee Training: Training staff on export control rules, recognizing "Red Flags," and blocking suspicious transactions.
- Screening System: Implementing procedures for automated or manual partner checks against sanctions lists.
- Audit and Monitoring: Creating internal audit mechanisms to verify system effectiveness.
- Record Keeping: Defining rules for archiving and storing export documentation in compliance with the law.
Common Scenarios and Needs
ICP is needed by:
- Large Exporters: With high turnover and complex supply chains.
- Tech Companies: Whose products (software, electronics) can easily be repurposed for military use.
- General Permit Seekers: Companies wishing to obtain a General Permit (simplifying procedures) are legally required to have an ICP.
- Logistics Centers: Controlling the flow of transit cargo.
Georgian Legal Framework
The Law of Georgia on Control of Military and Dual-Use Products directly encourages and, in some cases (for General Permits), mandates the existence of an Internal Compliance Program. This approach is based on the Wassenaar Arrangement and EU best practices. The existence of a program confirms that the company adheres to international security norms.
Step-by-Step Process
The process begins with a Management Commitment statement. The lawyer studies business processes and writes instructions. A compliance officer is appointed. Trainings are conducted. After system implementation, a trial period and correction of deficiencies take place. A comprehensive ICP is presented to the regulator to increase credibility.
Why Legal.ge?
An ICP is not just paper; it is a shield for your business. Specialists at Legal.ge will help you create a system that does not hinder your commercial activity but reliably protects you from violations. Our experience ensures your program meets international standards.
Updated: ...