The Ministry of Foreign Affairs for The Netherlands has issued guidelines for companies compiling an internal compliance programme (ICP) for “strategic goods, torture goods, technology and sanctions”. The Netherlands’ ICP guidelines resemble that of the EU’s guidance aside from the inclusion of shipment control (rather than physical and information security) in its 7 core elements.
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Michael is Senior Partner at Peters & Peters Solicitors LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters &...