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infoTheoretical penalty(s) of non-compliance subject to the judge's discretion and, where applicable, to certain conditions
  • 1 Revocabilitycourt hammer
    infoWithdrawal of the global license - Sanction decided following malfunctions observed during an inspection by the National Directorate for Customs Research and Investigation ('DNRED')

    Internal export control procedures for dual-use items benefiting from a global licence


    Scope of application

    Exports of a continuous stream of several dual-use items.

    Description

    An exporter who has a regular supply of dual-use items subject to authorisation and who wishes to obtain a global licence must, prior to any application, have filed with the Directorate-General for Competitiveness, Industry and Services, Dual-Use Items Department, a document describing all the following procedures, developed and applied within his company with a view to ensuring prior control of compliance with the principles governing the control of exports of dual-use items:

    • a) Internal verification of the nature of dual-use items to be delivered abroad according to the consignee;
    • b) Establishment and monitoring of a list of internal officials responsible for ensuring that export operations are, from the outset, carried out in accordance with the principles governing the export control of dual-use items;
    • c) The establishment of an internal audit programme to verify compliance with established procedures;
    • d) The establishment of a procedure to identify client companies that may not comply with export controls on dual-use items;
    • e) The establishment of a training programme for personnel handling orders subject to a global licence;
    • f) The establishment of a specific system for archiving reports of operations carried out and the documentary follow-up of orders, enabling the administration to obtain, if it deems necessary, information concerning exports carried out.
    The exporter states that the procedures described will be disseminated and effectively applied within the company.

    The control of the reliability and permanent application of the internal control procedures in place is the responsibility of the issuing authority.

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