Export control regimes restrict the transfer of goods, software and technology by destination, end use and end user.
Classification first. Determining the applicable control classification for each product and technology governs everything downstream. Misclassification is the root cause of most violations.
Deemed exports. Release of controlled technology to a foreign national within the country is treated as an export to their country of nationality. This catches research collaborations, engineering teams and vendor access.
End use and end user controls prohibit transactions with listed parties and for prohibited uses regardless of the item’s classification, including catch-all controls where the exporter knows or has reason to know of a prohibited use.
Red flags include reluctance to provide end use information, requests for unusual shipping routes, a customer whose business does not match the product, and requests to disable tracking or reporting features.
Screening. Restricted party screening at onboarding and at each transaction, including for personnel with access to controlled technology.
Recordkeeping for a defined period, and licence conditions tracked.
Voluntary disclosure is a substantial mitigating factor and is the central decision after a violation is found.
Sanctions overlap. Export controls and economic sanctions apply independently; compliance with one does not establish compliance with the other.