The Importance of an Internal Compliance Programme (ICP) for Academia under Malaysia’s Strategic Trade Act 2010

As our universities continue\ to advance in high-impact research and international collaboration, it is important that we uphold the highest standards of responsibility, ethics, and governance. I would like to take this opportunity to highlight the importance of establishing a robust Internal Compliance Programme (ICP) to support our academic community in aligning with the requirements of Malaysia’s Strategic Trade Act 2010 (STA).

The STA governs the export, transfer, and brokering of strategic items, including dual-use goods and technologies that may be repurposed for military or security-sensitive applications. While academia thrives on open inquiry, knowledge exchange, and cross-border collaboration, some of our research areas intersect with sensitive domains that require heightened diligence.

Implementing an ICP is not about restricting academic freedom — it is about protecting it responsibly.

Why an ICP Matters 

1. Ensuring Legal Compliance and Managing Risk
An ICP enables us to identify research, items, and technologies that fall under STA controls. It safeguards our scholars and institution from unintended violations, sanctions, or reputational harm by ensuring that sensitive information is not transferred or disclosed without authorisation.

2. Protecting Academic Freedom Through Responsible Research
With clear guidance, we can continue pursuing pioneering work while balancing national and international security considerations. An ICP provides a framework that supports open research without compromising ethical and security responsibilities.

3. Supporting Global Partnerships
International collaborations are vital to academic progress. An ICP clarifies procedures for due diligence, licensing, and reporting when working with foreign partners, institutions, and end-users — enabling us to engage confidently and transparently on the global stage.

4. Upholding Ethics and Responsible Innovation
We have a shared responsibility to reflect on the dual-use implications of our work. Embedding risk assessment into project planning, data sharing, and publication ensures that innovation remains beneficial and socially responsible.

5. Enhancing Operational Efficiency and Transparency
Standardising approval and record-keeping processes promotes smoother research administration, improves audit readiness, and reinforces institutional accountability.

6. Securing Research and Intellectual Property
A structured ICP helps protect sensitive research outputs, technologies, and intellectual property from misuse or misappropriation, with proper access control and responsible handling within our laboratories.

 

Core Components of an Academic ICP

· Governance & Ownership: Clear roles across leadership, compliance teams, research offices, and principal investigators.

· Risk Assessment: Regular dual-use risk categorisation for research activities.

· Due Diligence & Screening: Vetting collaborators, suppliers, and end-users.

· Controls on Exports & Publications: Guidance on licensing, cross-border transfers, deemed exports, and dissemination of dual-use research.

· Training & Awareness: Regular, role-specific training for academic, administrative, and laboratory personnel.

· Recordkeeping: Secure documentation of inventories, approvals, communications, and licensing.

· Incident Reporting: Safe channels to raise concerns and ensure corrective actions.

· Continuous Improvement: Internal audits and periodic policy updates aligned with regulatory changes and emerging risks.

 

Moving Forward: Practical Steps 

· Leadership Commitment: Endorsement and resourcing for compliance infrastructure.

· Policy Development: STA-aligned policies for research, licensing, and publication processes.

· Establishing a Compliance Office: A dedicated contact point for advice and support.

· Risk-Based Screening: Integrating compliance checks into grant proposals and project approvals.

· Training and Culture-building: Ongoing capability development and scenario-based exercises.

· Engagement with Authorities: Active partnership with relevant Malaysian strategic trade regulators.

· Technology and Data Controls: Secure systems for data classification, inventory, and access monitoring.

 

Benefits to the Academic Community

By embedding a strong ICP, we protect our scholars and university, enable safer and more fruitful international collaborations, and strengthen our standing as a responsible research institution. Most importantly, we build a culture of trust, transparency, and ethical research.

Our collective commitment to responsible research is essential to ensuring that our contributions to knowledge and innovation continue to serve society positively. A well-implemented Internal Compliance Programme will allow us to navigate dual-use research with confidence — safeguarding national interests while sustaining global academic engagement.

Let us work together to uphold a secure, ethical, and forward-looking research environment for the benefit of our institution and the wider world.

Warm regards,

Dr Tan Swee Leng, Olivia (Ph.D)