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Internal Compliance Programmes
 
Maintaining effective controls to prevent the diversion of materials and equipment capable of producing weapons of mass destruction (WMD) involves responsibility on both the Government as well as individual traders. Since Hong Kong is a major international commercial and trading centre through which large quantity of high technology goods are imported and exported everyday, traders must share responsibility in ensuring that goods passing through Hong Kong are not involved in WMD programmes. In the event that traders feel uneasy about any potentially sensitive or unusual order or approach for materials, information or scientific liaison, they should contact the Strategic Trade Controls Branch of the Trade and Industry Department for advice.
 
Laws have been enacted to forestall activities related to the development of WMD. All companies have an obligation to strictly comply with the Laws of Hong Kong. The establishment of an effective internal compliance programme, or Code of Practice, provides companies with a method of routinely screening transactions in order to eliminate suspicious approaches, thereby ensuring that only legitimate business transactions proceed and the risk of breaching the law in this area is minimised.
 
An internal compliance programme involves a company's commitment that its products will not be diverted to or used in weapons of mass destruction programmes. Vast majority of traders have no desire that their products be so used and wish to avoid such a possibility as much as they can. Implementation of an effective internal compliance programme is one way to demonstrate and ensure that this is the case.
 
Internal compliance programme differs from one company to another given the nature and size of the company concerned. Traders may refer to the following webpages for the core elements and guidance note on internal compliance programme:
Traders may also browse through the guidelines on Internal Compliance Programmes published by certain foreign control authorities for reference:

Programmes initiated by Trade and Industry Department
 
The Trade and Industry Department organises seminars regularly, and when substantial changes are made to the legislation and the control lists, to brief traders (including exporters, importers and carriers) of the strategic trade control system. In addition, circulars explaining licence application procedures are updated from time to time and are available to traders free of charge and can be downloaded from our website. Advice on licensing and decisions with regard to classification are also given readily by officers of the Trade and Industry Department either by telephone, in writing or in person.
 
In addition, the Trade and Industry Department welcomes traders to maintain a regular interaction with the Department so as to receive updates on any changes to the control lists by the international export control regimes and information on the licensing procedures maintained by the Trade and Industry Department.
Last Revision Date : 20 October 2023