James Calloway

Documented export compliance programs assigned ownership written procedures five-year records daily screening ECCN discipline SMB models versus dedicated officers ITAR empowered officials.

Model mid-size exporter sanctions screening payroll, displacement rates, integrations, penalty exposure benchmarks, plus trade compliance scope.

Sham-transaction-era expectations push exporters past roster hits into control proxies diverted routing ECCN-aware end-use order spikes automated rescreens and audited false-positive notes.

Four UFLPA sublists, 2025 sector priorities, convincing applicability packs, transshipped inputs that still trigger holds, and monthly supplier rescans across alias variants.

UKGT vs EU TARIC, five inputs for landed cost, TCA origin documentation traps, PVA and MPIVS reconciliation, TRA anti-dumping stacks the calculators skip, CDS, and the NI dual-tariff edge case.