Managing directors and board members are personally liable for breaches of foreign trade law arising from the company’s organisational deficiencies. This liability cannot be delegated. Management has four core responsibilities: organisation, personnel selection, information dissemination, and monitoring. These duties and their fulfilment must be integrated into the company’s internal export control processes. Only then can sanctions for misconduct be avoided or at least mitigated. Recent rulings show that ignorance is no defence against penalties, and that authorities and courts interpret compliance liability very broadly. Therefore, robust risk management and a well-structured internal export control system are essential for the effective management of export controls within a company.
Gain a comprehensive understanding of management’s responsibility for the internal organisation and oversight of export controls, and learn how to establish an Internal Compliance Programme (ICP).
• Prerequisites and function of the Export Control Executive
• Designation of the Export Control Executive
• Core duties of the Export Control Executive
• Internal Compliance Programme (ICP)
Managing directors, board members, heads of departments of EU and third-country companies