Focus area · EXC
Export-control and sanctions exposure along your trade routes
Sanctions regimes change constantly and reach deep into supply chains. We map which regimes apply to your goods, countries and counterparties, how they are enforced and where diversion risk sits.
What you sell, where it goes, who owns the buyer
Exposure arises from what you sell (dual-use and military goods, software, technology), where it goes, who uses it and who owns your counterparties. Since 2022 the sanctions landscape has expanded sharply, and authorities now focus on circumvention through third countries.
US rules can reach non-US companies through US-origin content, the US dollar or US persons. EU sanctions apply directly in every member state, and the EU has harmonised the criminal offences for violating them.
Legal frameworks we map
We map the regimes that apply to your footprint. Typical anchors:
- EU Dual-Use Regulation (EU) 2021/821
- Licensing of exports, brokering, transit and technical assistance for dual-use items, including cyber-surveillance items and catch-all controls.
- EU restrictive measures
- Country regimes such as Regulations (EU) No 833/2014 and No 269/2014 concerning Russia, asset freezes and anti-circumvention rules; Directive (EU) 2024/1226 harmonises criminal offences for sanctions violations.
- Germany: AWG and AWV
- The Foreign Trade and Payments Act and Ordinance, with criminal and administrative penalties; licensing by BAFA.
- US sanctions (OFAC)
- The Specially Designated Nationals list, the 50 percent rule and secondary-sanctions risk for non-US companies.
- US Export Administration Regulations (EAR)
- Controls on US-origin items, the de minimis and foreign direct product rules and the Entity List, administered by BIS.
- UK sanctions and export control
- Regimes under the Sanctions and Anti-Money Laundering Act 2018, enforced by OFSI and HMRC.
This is a risk analysis, not legal advice. Where a finding raises a legal question, we say so and you take it to counsel.
What we look at
External analysis
Your exposure as the outside world sees it.
- Applicable sanctions and export-control regimes per country
- Transshipment and diversion patterns relevant to your goods
- Enforcement cases in your sector and at your direct competitors
- Density of listed persons and state ownership among typical counterparties
Internal analysis (under NDA)
Your exposure as your own data shows it.
- Classification status of your products as you maintain it
- Customers, end users and distributors by country
- Intermediaries and freight forwarders in transshipment hubs
- Internal cases, screening hits and voluntary disclosures
Seven focus areas, mapped against every source we read.
| Module 1 · External analysis | Module 2 · Internal analysis (NDA) | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Focus area | Law & regulation | Enforcement record | Sector cases | Competitor cases | Indicators | Internal cases | Business partners | Sponsoring, donations, memberships | Gifts & hospitality |
| ABCAnti-bribery & corruption | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source |
| AMLAnti-money laundering | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Where relevant | Not used |
| ATRAntitrust & competition | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Core source | Where relevant |
| FRDFraud | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Where relevant |
| PRVData privacy | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Not used | Not used |
| EXCExport control & sanctions | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Not used | Not used |
| HRTHuman rights | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Not used |
Highlighted row: EXC · Export control & sanctions
Typical red flags
- New customers in known transshipment countries ordering goods with no plausible local use
- Vague or refused end-use and end-user statements
- Ownership changes at counterparties shortly after designations
- Payments from third countries or through unrelated parties
- Late routing changes or insistence on specific freight forwarders
- Common high-priority items such as electronics and machine parts sold to distributors near sanctioned markets
- Technical support or software updates for customers in restricted destinations
Sources
- Official sanctions lists and regulations of the EU, US, UK and UN
- Enforcement releases of OFAC, BIS, OFSI, customs authorities and prosecutors
- EU and US guidance on circumvention and high-priority items
- Trade data and press on diversion routes, used as indicators
- Court records
The report states the cut-off date of every list and regulation used.
Typically exposed sectors
Exposure tends to be higher for manufacturers of machinery, electronics, semiconductors, chemicals and aerospace components, for logistics and shipping, and for any company selling through distributors close to sanctioned markets.
A tendency, not a rating. Your actual exposure depends on business model, customer mix and footprint.
In your deliverable
- PDF: an export-control and sanctions chapter with regime map, diversion risk, enforcement cases, red flags and recommended measures
- Heatmap row per country × sector with the likelihood × impact rating
- XLSX: regime table per country with cut-off dates, case register and scoring sheet
- With the internal module: customers and distributors set against diversion and listing risk
Questions on export control and sanctions
Do you classify our products?
No. Product classification is a task for your export-control function or a specialist. We work with the classification status you have and show where exposure arises from destinations, counterparties and routes.
How current is the sanctions picture?
Sanctions change frequently. The report states the cut-off date of every list and regulation used, and the XLSX annex records the version. For fast-moving regimes we recommend a regular update.
Know your exposure before the next sanctions package.
Tell us your products, markets and sales channels. We come back with a scope proposal.