Service · Internal compliance programme
A compliance programme drafted for your business, and working in practice.
Authorities expect an internal compliance programme from any company that regularly exports controlled goods, software or technology. Some licences require one. Many companies have a manual; fewer have a programme their sales, engineering and logistics teams actually follow.
In two lines
We draft the policy, manual, procedures, templates and training for your products, destinations and systems, built on the EU's ICP guidance and aligned with UK, BIS, DDTC and OFAC expectations, then implement it and check it works.
What a strong programme covers
- Management commitment: a clear compliance policy, signed and backed by top management.
- Organisation and resources: defined roles with the time, authority and independence to act.
- Training and awareness: for compliance staff, sales, logistics, engineering and finance, each at the right level.
- Screening and decision process: classification, licence determination, sanctions and end-use checks built into how orders, shipments and technology transfers actually happen.
- Review and corrective action: regular checks, internal audits, escalation and follow-up.
- Record-keeping: complete, retrievable records of every decision.
- Physical and information security: protection of controlled technology and technical data, including email, cloud and AI tools.
We draft your programme
Tailored to your products, destinations, organisation and systems, and ready for management sign-off: a compliance policy statement; an ICP manual; procedures for classification, licence determination, screening, technology transfers, shipment holds and record-keeping; templates and checklists; training material for each team; an internal audit plan. Where an authority requires a programme, for example for an EU global licence, we draft it to that authority's standard and support you through its review.
How we work
- Gap assessment. Your current set-up against UK, EU and US expectations: documents, systems, interviews, a sample of real transactions. A short report with a prioritised action plan.
- Programme drafting. Policy, manual, procedures and templates, reviewed with your teams so they reflect how the business actually works.
- Implementation. Templates, checklists, integration into your ERP or compliance software, training for each team.
- Annual review. An independent check of how the programme works in practice, updated for rule changes, with a report to management.
When to call us
- You are applying for a global licence or an open licence that requires a programme.
- An authority has announced an audit or compliance visit.
- You have had an incident, a near miss or a voluntary disclosure.
- You are acquiring a company, entering new markets or launching sensitive products.
- Your programme exists but nobody is sure it is followed.
How it works
Scoping callFree, 30 minutes.
Gap assessmentFixed fee.
Drafting and implementationFixed-fee project, sized to your business.
Annual reviewYearly, combinable with training and health checks.
Start with the item you are not sure about.
A free 30-minute scoping call, or the 15-question assessment.