September 27, 2021


The new regulation of dual-use goods, which came into force on 9th September, provided for the drafting of an internal compliance program, in which companies must express their policy and the commitment of management regarding dual use legislation.

Only one piece was missing, to complete the mosaic of the new dual use legislation, or the definition of the rules to be followed in the drafting and control of internal compliance programs, namely the company evaluation, crystallized in a specific procedure, which identifies and defines subjects and responsibilities, analyzes the characteristics of the exported products, verifies their compliance with the legislation, both in objective terms and in terms of the potential danger linked to the marketing of the products themselves, foreshadowing the risks related to their use. The EU Commission has chiseled the missing card, publishing Recommendation (EU) No 1700/21, which outlines “a framework to help research organizations and researchers, research managers and compliance staff to identify, manage and mitigate the risks associated with export control of dual-use items as well as facilitate compliance with relevant EU and national laws and regulations”. Attention: an unconstrained recommendation (tautological), which does not exempt operators from the obligations of the regulation recently in force. Now the tools are there, let the party begin.

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