Dual-use, licensing, screening and embargo practice
Article 4 catch-all controls apply when you are 'aware' the items may be intended for WMD or military end-use. Our auditors want to see how we evidence the absence of such awareness for routine orders. Do you keep a written end-use assessment for every export, or only for flagged lanes? What does your paper trail look like?
Our product bundles a US-origin encryption library (ENC-restricted, 5D992 self-classified) into otherwise non-US software. Before we re-export from Singapore to a customer in an E:1-adjacent market: does anyone have a worked de minimis calculation for software where the US content is a linked library rather than source? My percentages feel hand-wavy.
Follow-up thread from May's session. The escalation memo template Hans mentioned is attached to the first answer. Screening-cadence questions keep coming in, keep them coming.
