The Export Control Executive: Liability and Risk Management

Managing directors and board members are personally liable if found in violation of foreign trade law resulting from the company's organisational deficits. This liability cannot be delegated. The management has four core duties: organisation, personnel selection, information and monitoring. It is essential that these obligations and their fulfillment are integrated into the internal export control processes. Only then can sanctions for misconduct be averted or at least reduced.

The authorities and courts understand liability for compliance very broadly and contemporary rulings show that ignorance does not protect against punishment. Therefore, risk management and organisation for internal export controls are essential for the efficient export control management of a company.