In its 2019 guidance, the European Commission set out recommendations on internal compliance programs (“ICP”) for dual-use trade controls. These include suggested good practice for, among other things, management, training, screening and recordkeeping. In this article, we consider good practice as it relates to the latter, how records should be made and maintained, and when it is safe to throw records away if you have operations in the EU (and UK).
What does the EU Commission expect?
The ...
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