TFITrade Finance Intelligence
Advisory · Export control

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.

Typical situations

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).
Services

What we do for you

  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. 06

    Training and audit

    Training for sales, order processing and logistics; internal ICP audits with an action plan.

  • 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)
FAQ

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.

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.