WebinarQ&A: Sanctions screening for SMEs: templates and follow-ups
Export Controls & SanctionsHans Müller23 May143
Hans Müller
Founding No. 5ExpertITI memberExport Control Officer · Rheinland Maschinenbau
de · Germany · Member since 3 Jun 2026
20 years in dual-use licensing for industrial machinery. The catch-all clause keeps me up at night so it doesn't keep you up.
Export ControlsSanctions ScreeningCompliance Audits
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Asked by Hans
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3d ago16 likes
EU dual-use catch-all: how do you document the 'knowledge' standard in practice?Documenting a negative ('we were not aware') is the wrong frame, document the process instead. Ours: (1) every order passes a red-flag checklist embedded in order entry; (2) flagged lanes get a written end-use assessment with a named reviewer; (3) unflagged orders inherit the lane-level assessment, refreshed annually. Auditors have accepted this twice. A per-export memo for every routine shipment is neither required nor sustainable.
6d ago9 likes
Moved from freight ops into compliance: how do I get management to take the function seriously?Invite your management to one webinar here. Watching a hundred professionals discuss the same risks normalises the function faster than any internal memo.
6d ago14 likes
CBAM report kicked back over default values, what now?What passed our registry review: a dated request letter on letterhead citing the specific CN codes, a follow-up at 30 days, a final notice quoting the contract's data clause, and the supplier's written refusal. Emails alone were not enough, but emails plus one formal letter were. Keep them in the entry file, not in someone's inbox.
23 May9 likes
Q&A: Sanctions screening for SMEs: templates and follow-upsYes, screen at payment too, your bank screens for THEIR risk appetite, not your licence conditions. Their clean pass is not your defence file. It costs you seconds; the asymmetry decides it.