Export control with a system – from item master to end use.
Anyone exporting goods, software or technology is responsible for classification, licensing and end use – including deliveries through distributors and third countries. We build an internal compliance programme with you that fits your business and stands up to scrutiny by the licensing authority and customs.
When to bring us in
- You are entering new markets or product areas and need a structured ICP for the first time.
- Classification lives in individual people’s heads rather than in a documented process.
- Customers in third countries order unusual volumes of Common High Priority List items.
- Your bank asks for export-control evidence before issuing letters of credit or guarantees.
- A breach has been found: the facts need to be worked up so that you and your counsel can decide on a possible voluntary disclosure (in Germany, § 22(4) AWG covers negligent administrative offences only).
What we do for you
- 01
ICP design and review
An internal compliance programme following Commission Recommendation (EU) 2019/1318 and national authority guidance: responsibilities, processes, record-keeping, training and audit.
- 02
Classification
Method and item-master process for Annex I of the Dual-Use Regulation, national control lists and the goods annexes of the Russia sanctions, reconciled with customs tariff codes.
- 03
End use and customer checks
End-use statements, plausibility checks, catch-all assessment (Articles 4 and 5 of the Dual-Use Regulation) and red flags for diversion via third countries.
- 04
Embargoes and goods bans
Russia and Belarus goods lists, the contractual “no Russia” clause, the Common High Priority List and Iran restrictions – mapped against your supply chains.
- 05
US re-export controls
An assessment of when the US Export Administration Regulations apply to US-origin items or US content – with specialist US counsel where needed.
- 06
Training and audit
Training for sales, order processing and logistics; internal ICP audits with an action plan.
Deliverables that last
- ICP manual with roles and processes
- Classification method and review records
- End-use and customer check template
- Red-flag catalogue for diversion routes
- Audit report with action plan
- Training materials and records
Our tools for this
One access point for country risk, regulatory change and reviews – the results of our advice keep running here day to day.
EU and US export controls as official layers (EU general export authorisations EU001–EU008, EAR country groups), plus the EU anti-circumvention tool and evidenced trade routes.
Checks goods in trade finance transactions by HS code, catch-all terms, end user and destination; goods without an HS code are held.
Changes at the EU, BIS and national authorities, new goods lists and enforcement cases – summarised daily.
- Dual-Use Regulation (EU) 2021/821
- Commission Recommendation (EU) 2019/1318 on internal compliance programmes
- German Foreign Trade and Payments Act (AWG) and Ordinance (AWV), national control list
- Regulation (EU) 833/2014: Russia goods bans, Art. 12g
- Common High Priority List (EU, US, UK, Japan)
- US Export Administration Regulations (15 CFR 730–774)
- Guidance of the German Federal Office for Economic Affairs and Export Control (BAFA)
Frequently asked questions
We are not a financial institution – is your advice still a fit?
Yes. Export control mainly concerns companies that export goods. Our trade finance background is an advantage here: we know which evidence banks expect for letters of credit and guarantees.
Do you replace our export control officer?
No. Responsibility stays with your management and the board member designated as responsible for export control (Ausfuhrverantwortlicher). We support them with method, documentation, training and an independent outside view.
Do you classify our goods?
We establish the method and review samples and borderline cases together with your engineers. Binding rulings come from the licensing authority; we help you prepare the request.
Other practice areas
Export control: let’s talk about your case.
In a demo we show you TFI TradeCore on your products, countries and use cases – and discuss where advisory or an audit gives you the most leverage. No obligation, confidential, and with specialists in trade finance.
or write to info@tradefinance-intelligence.com