Specialisation / Export controls

Export controls,
held to the line.

For defence and dual-use suppliers working across UK, EU and US regimes. One programme, however many regulators it answers to.

225 FT 4 IN Westminster Abbey · west front HAWKSMOOR TOWERS · PORTLAND STONE · 1745
UK · EUECJU & OFSI
288 FT United States Capitol · east front NEOCLASSICAL · CAST-IRON DOME · 1866
United StatesITAR & EAR
Elevations · Not to scaleLondon · Washington
§ A — How we help

Posture, programme, transaction.

Where exposure spans more than one regime, the programme is built with all of them in view.

Posture

Where your controls stand, and whether they would hold under a regulator's or a prime's scrutiny.

Programme

A compliance programme that fits the operation, and is handed over ready to run.

Transaction

The consignee, the end user and the end use, before anything ships.

§ B — Regimes

The frameworks we work within.

We draft within these regimes. We do not certify against them or represent compliance with them.

Export Control Order
UK · 2008

The Military List, the dual-use schedule and trade controls, including UK persons abroad.

Financial sanctions
UK · OFSI · SAMLA 2018

UK designations, ownership and control, and the duty to report.

Dual-Use Regulation
EU · 2021/821

EU dual-use controls, catch-all provisions and the expectation of a compliance programme.

ITAR
US · 22 CFR 120–130

Defence articles, services and technical data on the Munitions List.

EAR
US · 15 CFR 730–774

Dual-use items, end-user and end-use controls, and the Entity List.

OFAC
US · 31 CFR Ch. V

US sanctions programmes, including the 50 per cent rule.

Supplier assurance
DFARS · NIST 800-171 · CMMC · JSP 440 · Def Stan 05-138 · AQAP

The cyber and quality regimes that travel with a defence contract.

§ C — Dual exposure

When one supplier meets two regimes.

Most defence work lands in more than one regime. The programme is designed for that from the start.

Case 01

UK supplier, US prime

UK export controls on one side, ITAR or EAR on the other, and cyber obligations flowing down from the prime. One management system, one set of records.

Route · UK programme + US overlay
Case 02

US content, UK or EU product

US-origin components carry re-export obligations wherever the product is built. The programme has to follow them through the bill of materials.

Route · Local programme + re-export tracking
When to call

A prime is asking. A licence is due. A shipment is live.

We do not classify goods or determine licensability. Those rest with the client, counsel or the regulator.

Defence & aerospace →

Next step

We keep things moving.

A bid, an audit, a counterparty or a contract. Send it over, and we will come back with scope, fee and timeline within 24 hours.

Send a brief →— Reply within 24h
Container port elevation A densely detailed front-elevation line drawing of a container port in brass on deep navy. A large container ship with a raked bow, hull plating, draft marks and an accommodation block carries eleven bays of stacked containers. Two ship-to-shore gantry cranes stand on the quay: one with its latticed boom lowered over the ship, a trolley and a container suspended on the spreader, the other with its boom raised. To the right a rail-mounted gantry spans stacked yard containers. Water is drawn as layered wave lines with reflections; the quay carries crane rails, bollards, fenders and mooring lines.
Container terminal · Elevation