⚖️ Legal notice
This checklist is intended for general informational purposes only and does not constitute legal, tax or compliance advice. Although the content has been compiled with care based on current legislation and regulations, no rights may be derived from it. Always consult a qualified adviser for your specific situation.
STEP 1 · Check your product
Is your product listed on the EU dual-use control list (Annex I, EU Regulation 2021/821)?
Does your product have a military application in addition to its civilian use — even if that is not the intended purpose?
Is an export licence required? Consult your national export control authority for guidance — in the Netherlands submit the application to the CDIU; in the UK to the ECJU (Export Control Joint Unit).
Is your product not on the control list but do you have indications of military end-use? The catch-all obligation then applies: notify the relevant national export control authority.
Does the invoice contain the correct HS code and product specification? A missing or incorrect HS code may be interpreted by customs as evidence of intentional circumvention.
Are you also sending software, technical documentation or knowledge? Intangible Technology Transfer (ITT) also falls under export control — including transfers by email or cloud.
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Note: Annex I was significantly expanded in November 2025 to include quantum technology, semiconductor manufacturing equipment and biosecurity items. Check whether your product has been added to the list as a result of this update.
STEP 2 · Investigate the customer and end-user
Does the customer have a demonstrable business activity that logically explains the intended use of your product?
Does the customer have technical knowledge of the product — or does the order not match their profile?
Is the customer newly incorporated, with no website, no staff and no visible activities?
Have you conducted a beneficial ownership investigation on the customer and on any intermediaries or brokers?
Is an intermediary or broker involved? If so: has the Ultimate End-User (UEU) been fully identified and screened?
Is the End-User Certificate (EUC) plausible? A company with no relevant activities ordering precision technology "for civilian use" does not constitute a credible declaration.
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A customer without technical knowledge ordering advanced technology is a classic indicator of a front company. An EUC alone is not sufficient — the plausibility of its contents must also be assessed.
STEP 3 · Check the destination and trade route
Is the final destination of the goods known and documented — not merely the direct delivery address?
Does the trade route pass through a neutral transit country (Turkey, UAE, Kazakhstan) while the end-user remains unknown?
Is the destination country — or any country along the route — on the EU high-risk third countries list or a sanctioned country?
Is the chosen transport route commercially logical and economically justified for this type of goods?
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A route through a neutral country without an explanation for the detour is the strongest indicator of re-export to a sanctioned country.
STEP 4 · Conduct sanctions screening
Is the customer, end-user or intermediary listed on the EU Financial Sanctions File (FSF)?
Is any of the parties involved listed on the OFAC SDN list (US) or the UK Sanctions List?
Has the interest of a sanctioned party been deliberately kept at just under 50% in an entity involved in the transaction?
Have you verified the payment: does it originate from the contracting party itself, or from an unknown third party?
Does your product contain US-origin components or technology? If so, the US re-export rules (EAR/BIS) may also apply — a separate framework in addition to EU regulations.
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Sanctions screening applies to all parties in the chain — not just the direct customer. Also consider indirect US jurisdiction arising from US-origin components.
STEP 5 · Assess the overall picture
Can you explain the full transaction — customer, product, route, end-user — to your bank or regulator without it sounding forced?
Have you received an End-User Certificate (EUC): a written statement from the customer regarding the intended use and final destination?
Is there no time pressure? Pressure to deliver quickly without room for verification is a classic manipulation technique.
Have you documented all findings in an export file? Retention requirement: minimum 5 years.
Does your company have an Internal Compliance Programme (ICP)? This is formally required for certain EU export authorisations and is expected by your bank as part of due diligence.
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In the event of an inspection by the relevant enforcement authority, you must be able to demonstrate that you acted with due care. Without a documented file and ICP, your position will be weak.
💬 The question you must always ask:
Can the customer provide a written End-User Certificate that logically explains the product, the intended use and the final destination? If they cannot or will not, the outcome of your investigation is by definition insufficient — regardless of how legitimate the order appears at first glance.
🚨 STOP — do not ship if:
- ⛔The final destination is unknown or the customer refuses to disclose it.
- ⛔The trade route passes through a neutral country without a commercial explanation for the detour.
- ⛔The customer or any party in the chain is listed on a sanctions list.
- ⛔The customer has no technical knowledge of the product and cannot explain the intended use.
- ⛔There is pressure to deliver quickly without time for verification or documentation.
- ⛔You require an export licence but have not yet applied for one with the competent authority (CDIU / ECJU).
- ⛔Your bank has identified dual-use risk signals — your transactions may be blocked and your account frozen, independently of any criminal proceedings.
Concerned about a customer, order or trade route?
End-user check
Sanctions screening
Beneficial ownership investigation
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