Zhengdao AIZHENGDAO.AI

Compliance health self-check

The 9 questions below map to the nine elements of an Internal Compliance Program (ICP)(following China's Ministry of Commerce Guidelines on Internal Compliance for Dual-Use Item Export Control). Answer honestly based on your current state — 3 minutes to a result.

This self-check is an educational self-assessment tool; results are for reference only, do not constitute legal advice, and do not represent any regulator's determination. Your answers are computed only in your browser and are never uploaded or stored.

1. Policy statement — Do you have an export-control compliance policy statement, signed by the chairman/GM and known to all staff?
2. Organisation — Is there a clear compliance owner (or department) with veto power over high-risk transactions?
3. Risk assessment — Do you periodically assess and grade control risk across product, customer and destination dimensions?
4. Review procedures — Does each export pass a review of product, counterparty, end-use and shipping?
5. Emergency measures — On discovering a suspected violation, is there a clear stop/report/handle plan?
6. Training — Have key roles (sales, logistics, R&D) received export-control training?
7. Compliance audit — Have you internally audited or externally checked how the compliance rules are executed?
8. Records — Are review records, licences and end-user statements filed and kept for 5+ years?
9. Compliance manual — Is there a written compliance operating manual, updated within the last year?

Practical verification checklist

Scope · evidence · decision trail

Use the steps below to review this page. Verify the complete official text before making a decision. Seek qualified advice when needed.

  1. Define the decision

    State the exact decision, owner, deadline, trade direction and required evidence. Do this before you search.

  2. Identify every party

    Confirm each legal name and alias. Check registration, ownership, control, intermediaries, carriers, banks and beneficial owners.

  3. Describe the item

    Record the item’s function, operating principle, material, model and performance. Include software, technology, accessories and decisive parameters.

  4. Check classification

    Treat customs and export-control classification as separate tasks. Keep the facts, assumptions and reasoning for each result.

  5. Map the route

    Confirm origin, departure, destination and transit points. Include re-export, remote access, technology transfer and each delivery path.

  6. Verify end use

    Identify the stated purpose and real operating environment. Check integration, sensitive sectors, military links and prohibited uses.

  7. Verify end users

    Check the purchaser, consignee, end user, operator and parent company. Identify anyone who can redirect or control the item.

  8. Read the complete source

    Treat a search result as a lead. Read the official scope, definitions, notes, exclusions, annexes and licence conditions.

  9. Check current measures

    Use the version effective on the transaction date. Review later notices, temporary controls, destination measures and policy changes.

  10. Test exceptions carefully

    Prove every condition before using an exception or exemption. Apply the same rule to licence facilitation and general authorisations.

  11. Resolve contradictions

    Pause when names, codes, documents, routes, prices or explanations conflict. Obtain evidence instead of filling gaps with assumptions.

  12. Escalate uncertainty

    Send unresolved questions to the compliance owner or a qualified adviser. This includes classification, ownership, use, destination and licensing.

  13. Keep an audit trail

    Keep source links, files, checksums, screenshots, search terms and results. Record the reviewer, approvals and final reasoning.

  14. Schedule re-checks

    Set a new review date for open transactions. Re-check changing parties, destinations, specifications, official lists and licences.