An Internal Compliance Program (ICP) is a system through which enterprise internally manage their own export control processes to ensure compliance with domestic export control laws. Around the world, ICPs are actively utilized as a means of export control for strategic items. However, they are not mostly applied to the Trigger List Items. However, advanced countries such as the United States and the Nuclear Suppliers Group (NSG) have been actively researching the potential application of ICPs to the Trigger List Items recently. This paper suggests additional considerations that should be taken into account when applying an ICP to the Trigger List Items. The key elements of classical ICP include Top-level management commitment to compliance; Risk analysis; Organizational structure/chain of responsibilities; Human and technical resources allocated to the management of exports; Workflow management and operational procedures; Record -keeping and documentation; Selection of staff; training and awareness-raising; Process-/Systemrelated controls (ICP audit)/Corrective Measures; Physical and technical security. An ICP for Trigger List Items must encompass all these core elements. Additionally, as the nuclear industry often involves collaborative projects participating with various companies, the effectiveness of the ICP could be enhanced through the operation of consultation groups among participating companies. Furthermore, enterprises must take into account the unique characteristics of Trigger List Items that differ from other strategic items, when making requirements of the ICP establishment. First, export requirements related to safety measures and physical protection should be reviewed to export the Trigger List Items. The procedure and obligations in aspects of internationally controlled items should also be reviewed. Moreover, active support from enterprises for GTGA procedures should also be included, since the Government to Government Assurance (GTGA) procedure is additionally required for the export of Trigger List Items, in contrast to other strategic items. Additionally, for materials categorized within Trigger List Items, such as deuterium and heavy water, should be controlled based on their end-use and cumulative quantity, which Government cannot effectively manage without enterprise supports. Therefore, enterprises must establish an internal material management system based on the end-use and cumulative quantity of these materials under ICP.

• Su-Hyeon Kim(Korea Institute of Nuclear Nonproliferation and Control (KINAC))
• Chansuh Lee(Korea Institute of Nuclear Nonproliferation and Control (KINAC)) Corresponding author