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Violations can lead to criminal penalties and loss of export privileges.

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EU Dual-Use Regulation (2021/821)

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The "Recast" Regulation has modernized EU export controls, introducing stricter controls on cyber-surveillance items and expanding the definition of "exporter"[cite: 21, 52].

We assist organizations in classifying items under the Control List (Annex I) and managing the full licensing lifecycle:

  • Classification: Determining ECCN (Export Control Classification Number) vs HS Codes.
  • Licensing: Management of Individual, Global, and General Export Authorisations (EU GEAs).
  • Catch-all Clauses: Assessing risks for non-listed items intended for military end-use.

US Extraterritoriality: ITAR & EAR

For European companies, the risk often lies in the De Minimis rule and the Direct Product Rule. We provide governance for:

ITAR (State Dept)

Strict control on Defence articles. [cite_start]Management of TAA (Technical Assistance Agreements) and DSP licenses for re-export[cite: 21].

EAR (Commerce Dept)

Management of the "Commerce Control List" (CCL) and De Minimis calculations for US-origin content incorporated abroad.


Sanctions & Restricted Parties

Sanctions compliance goes beyond simple list checking. We implement Enhanced Due Diligence (EDD) frameworks covering:

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  • Screening Workflows: Automated screening against Consolidated Lists (EU, UN, OFAC SDN, UK UKSL)[cite: 8].
  • Circumvention Risk: Identifying "red flags" in shipping routes and end-user statements.

Internal Compliance Program (ICP)

We design and audit your ICP based on the EU Commission Recommendation (2019/1318). An effective ICP is mandatory for certain General Licenses and serves as a mitigating factor in case of inadvertent violations.

  • Top-level commitment statement
  • Transaction screening procedures
  • Training & Record keeping
  • Reporting & Corrective actions

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Avoid border delays and regulatory penalties.

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