for Strategic Trade Control Compliance

It is your enterprise’s responsibility to develop a strategy for effective ICP development and implementation. Developing and implementing an ICP requires time, resources, and technical expertise. Unfortunately, enterprises often underestimate the amount of time it will take to develop an ICP and fail to dedicate the resources required to support its effective implementation. Drafting an ICP Development and Implementation Plan can help to ensure that your ICP is properly instituted and can be implemented in an effective and sustainable manner.

The table below outlines a multi-step plan for developing and implementing an ICP within your enterprise.

Developing and Implementing Your ICP Tasks to be Completed
Step 1 Gather Knowledge
  • Compile relevant laws and regulations; determine legal obligations and other requirements with which your enterprise must comply
  • Isolate the enterprise's compliance risks and vulnerabilities (business, activities, country, commodity, and end-use profiles)
  • Determine the extent to which your enterprise deals in controlled items
  • Evaluate extent of in-house technical expertise
  • Assess current resources and estimate the time required to establish and maintain the ICP (better to overestimate)
  • Evaluate the overall cost to establish and maintain the ICP *

* Establishing an ICP carries costs and your enterprise must commit the appropriate resources (time, financial and human) to ensure effective implementation. Initial ICP set-up costs will likely be less than 2% of your enterprise's annual turnover (total sales) and the running costs to implement an ICP is generally estimated at less than 1% of annual total sales.

Step 2 Review Current Practices and Procedures
  • Review all written standard operating procedures (SOPs)
  • Review enterprise products and technology (includes classifying commodities and determining which goods or technology are subject to STC licensing requirements in your country).
  • Identify internal and external STC and ICP resources that can assist with ICP development and maintenance (includes technical specialists, external consultants, legal counsel, auditing firms, non-governmental organizations, academia, etc.)
  • Define the scope of your enterprise's ICP and determine the specific Elements of the ICP

Note: These tasks may require interviews with relevant business units or sales and technical personnel (engineers, scientists, etc.) in order to determine current procedures and the technical specifications of each of your enterprise's products.

Step 3 Develop an ICP Manual
  • Draft the "ICP Manual" that maintains step-by-step, internal processes and written SOPs for implementation of the ICP
  • Custom-tailor the ICP to the scope of your enterprise's activities and specific business circumstances
Step 4 ICP Implementation
  • Publicize and announce adoption and implementation of the ICP enterprise-wide
  • Initiate training and awareness-raising efforts for all relevant staff
  • Distribute guidelines for implementation and the ICP Manual to all relevant personnel
  • Identify empowered STC compliance officials and communicate ICP organizational structure (including the chain of command)
  • Allocate necessary financial resources and put in place operational support to enable effective ICP implementation
  • Establish expectations for employees tasked with compliance functions
Step 5 Ongoing ICP Maintenance
  • Conduct regular ICP audits and review the ICP for effectiveness
  • Monitor changes to national STC requirements and update the ICP to account for legislative amendments, control list updates, and other changes to the national STC system
  • Regularly review and update product classifications for new and existing goods/technologies
  • Conduct continuous STC training for employees
  • Evaluate changes to business practices and identify emerging compliance risks (e.g. new customers, markets, or products or new proliferation trends)
  • Revise the ICP to account for and address identified compliance risks and vulnerabilities

Note: Your enterprise should consult with the national authorities to determine if there are ICP requirements, national guidelines, incentives, and/or resources available to industry in your country.