What does an internal compliance programme contain?
Unofficial translation from the Vietnamese original.
Clause 2, Article 5 of Decree No. 259/2025/ND-CP requires six sets of procedures: commitments by the trader, the owner, departments and staff; screening of end users and end use; keeping up to date with the law; internal training; record keeping; and notification duties. Detailed requirements are in Appendix II.
Article 18 of Law No. 13/2026/QH16 is broader: risk identification, assessment and management; control of end users and end use; information management and record keeping; training, review, evaluation and updating of the programme; and mechanisms to detect, report and handle internal violations.
The programme may stand alone or be integrated into existing governance and internal control systems (clause 2, Article 18).