The recent swift implementation of UK Russian Sanctions has highlighted the importance of End-Use due diligence to exporting businesses, sanctions being an issue that many UK businesses had not considered until the crisis arose in Ukraine. End-Use of goods subject to strategic controls has always been a compliance requirement and evidencing due diligence to that requirement may only become apparent at audit.

UK businesses are also facing challenging compliance issues post EU Exit. 

Businesses that traded solely with EU businesses before the UK left the EU have been particularly impacted, having had less exposure to international trade regulations until the compliance requitement hit in 2021.

Strong and Herd can help interpret the relevant regulations into working business activities, identifying goods and practices in regulatory terms, to increase a business understanding of the compliance requirements, giving a thorough understanding of what is to be expected at, and prepared for during an ECJU or HMRC audit.

Some key business focus areas for an Export Control Audit:

• UK Export Controls: UK export licencing, including but not limited to military and dual use controls
• US extra-territoriality controls, ITAR, EAR and US Sanction controls
• Other country controls including EU regulatory compliance
• Evidencing Due Diligence, End Use and Sanctions controls
• Preparation of robust compliance processes
• Preparation of ECJU Pre-Visit Questionnaire
• Preparing for a Voluntary Disclosure

Focus On: Preparing for an Export Control Audit

As part of our new “Focus on…” sessions Strong and Herd’s Gail Leeson & Steve Berry will guide the licence holder to prepare for an audit by understanding what will be required prior to the auditors visit, what will happen on the day and the information required together with post audit next steps.