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Title: Directions to Identify Companies Implementing the Internal Compliance Program Ch
Date: 2024.04.15
Legislative: 1.Promulgated on August 8, 2012
2.Amendments to Articles 4, 5 and 6 promulgated on January 28, 2015
3.Amendments to Articles 3 and 5 promulgated on August 22, 2019.
4.Amendments on April 15, 2024
Content: 1.    The International Trade Administration (hereafter referred to as TITA) under the Ministry 
of Economic Affairs has set forth these instructions to identify exporters that implement the 
Internal Compliance Program for exportation of Strategic High-Tech Commodities (SHTC).
2.    An exporter can submit written documentation to the TITA for identification concerning 
implementation of the Internal Compliance Program within the company.
3.    The company’s Internal Compliance Program should set up the following management 
items and screening lists (contents of the management items and screening lists are available on the 
TITA’s website:
(1)    Management items:
a.    The company’s official statement: It should be provided to all em-ployees and outline the 
company’s intention to implement the In-ternal Compliance Program for exportation of Strategic 
High-Tech Commodities (SHTC).
b.    Authorization and responsibility: The accountability and responsi-bility of employees 
should be delegated according to the compa-ny’s organizational structure.
c.    Record keeping: Complete management and transaction files should be kept.
d.    Training programs: Regular training and instruction of employees should be provided to 
those involved in export-related activities.
e.    Information circular: Standard procedures should be in place to notify the company’s 
department in charge of export control if the staff encounters suspicious transactions.
f.    Order processing: Written standard procedures for the processing of orders should be in 
place to implement screening and document cross-checks for the exportation of SHTC.
g.    Internal review: All departments of the company should be audited and reviewed regularly 
to ensure that they comply with the company’s Internal Compliance Program procedures. 
(2)    Screening lists:
a.    Screening according to the Entity List for SHTC:
The exporter should screen its transaction parties in accordance with the Entity List for SHTC as 
announced on the TITA website. If a transaction party is found to be on the Entity List for SHTC, 
the exporter should reject the transaction or apply for an export permit from the TITA with 
supporting documents.
b.    Screening according to the Export Control List for SHTC:
The exporter should screen commodities for export to determine whether they are on the Export 
Control List for SHTC and correctly identify the export control classification number for relevant 
products. The exporter should apply for an export permit when commodities for export are 
included on the Export Control List for SHTC.
c.    Red flag screening:
The exporter should establish a red flag list for aberrant transactions based on the characteristics of 
the commodities. Notification of aberrant transactions should comply with standard procedures in 
the information circular so that the department in charge of export control can decide whether to 
reject the transaction or provide supporting documents for an export permit application to the 
4.    An exporter that implements the Internal Compliance Program (hereafter referred to as ICP 
Exporter) and is identified by the TITA can enjoy privileges granted under Articles 15, 15-1, 16, 
and 17 of the Regulations Governing Export and Import of Strategic High-Tech Commodities 
(hereafter referred to as The Regulations) when applying for export permits for SHTC from the 
5.    An ICP Exporter should upload the digital file on customs clearance transaction details for 
the SHTC export permit to the TITA’s Electronic Visas for Export and Import Commodities system 
before the deadlines listed below for a TITA audit.
(1)    Submitting data from October to December of the previous year before March 31of each 
(2)    Submitting data from January to March before June 30 of each year.
(3)    Submitting data from April to June before September 30 of each year.
(4)    Submitting data from July to September before December 31 of each year.
6.    An ICP Exporter should summit an internal review of the previous year to the TITA before 
Mach 31 of each year in accordance with Article 15-1 of The Regulations. The TITA may conduct 
document or on-site inspections to review the internal compliance procedures of the ICP Exporter.
7.    The ICP Exporter should summit written documents to the TITA for each red-flagged 
transaction that was denied.
8.    The TITA will nullify the ICP Exporter’s qualifications and revoke the export permit 
referred to in paragraph 1 of Article 15-1 of The Regulations if there are violations that match the 
circumstances stated in paragraph 3 of Article 15-1 of The Regulations.
9.    An ICP Exporter whose qualifications have been nullified for over one calendar year can 
re-apply for re-identification from the TITA.