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Know your buyer.
Before you ship.

We vet the buyer of restricted AI hardware, and every party in the deal.

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Buyer vetting file
CEU-2026-0912-0417
Sample
BuyerMeridian Compute Holdings Ltd IE
SiteNoordkade DC2, Hall 3 · Groningen NL
OrderPO 4417-A · 32 × 8-GPU H100 system as declared by seller
DatesOpened 2026-09-03 · Released 2026-09-12
Checks
  • Purchase-order declarationSigned
  • Ownership and headquartersVerified
  • Transaction review1 flag · resolved
  • Operator statementReceived direct
  • Screening · 14 partiesNo match · 09-10
  • Site inspection pilotAfter delivery
Ownership and headquarters
Meridian Compute Holdings Ltd · HQ IE
└ 100% Meridian Group BV · HQ NL
└ 62% A. Verhoeven · NL
└ 38% Ostrava Capital LP · LU

LP looked through to its partners. No listed party at any level.

Finding Proceed with conditions

Ship direct to the facility. The forwarder's address first given as ship-to is not accepted.

The rules put the burden on the seller.

Export controls on advanced computing chips do not stop at the OEM. Anyone who sells, resells or brokers restricted GPUs and AI servers is expected to know their customer, screen every party, and have a reasonable basis to believe the stated end use is real.

EXPOSURE

Criminal and civil penalties.

Willful violations of the Export Administration Regulations carry penalties of up to $1 million and 20 years per violation. Civil penalties run to the greater of roughly $374,000 or twice the transaction value, per violation. Either can also cost you your export privileges.

TODAY

Slow and expensive.

A law-firm review of a single buyer takes one to two weeks and bills by the hour. Deals wait. Some die. A list-screening tool tells you a name is not on a list, and nothing else.

THE GAP

Nobody checks after shipment.

In a case charged in October 2026, prosecutors allege a California reseller moved more than $300 million of GPU servers with Malaysia and Singapore on the paperwork, and that the hardware went on to China. The declared destinations were legal. Only a statement from the facility and a visit to it reach past the paperwork.

Two services. Sold separately or together.

Pre-shipment

Buyer vetting

Your buyer signs a declaration on the order and answers for their ownership, their facility and the deal itself. The facility operator confirms directly to us. We screen, map and challenge, and return a documented diligence file you can put in front of counsel or a regulator.

  • A signed declaration on every purchase order
  • Ownership and headquarters traced to the ultimate parent
  • The deal tested: destination, facility, quantity, funding
  • A statement from the facility operator, sent to us directly
How buyer vetting works →
Post-shipment

Installation verification

An independent inspector attends the installation site, confirms the hardware is where the buyer said it would be, records serial numbers, photographs the racks, and documents chain of custody. Delivered under NDA to you and to the site operator.

  • Serial numbers reconciled against your shipping manifest
  • Site capacity observed: power, cooling, network
  • Timestamped photographic record
  • Scoped so the operator never hands configuration data to a counterparty
How installation verification works →

The diligence large manufacturers run in-house. Without the department.

A list-screening hit rate of zero tells you very little. These are the checks that tell you more.

1

A declaration on every PO.

Commercial or military use, a specific end use, weapons and proliferation, sanctioned destinations, the named end user and installation country, and written consent to inspection after delivery.

2

Ownership and headquarters.

The chain to the ultimate parent, each headquarters checked against the public record, and the 50 percent ownership test applied in aggregate.

3

GPU-ready systems.

Whether accelerators will be added after purchase, and which model, asked and signed on every order.

4

Whether the deal makes sense.

Final destination against staging address, leased megawatts against the order, quantity against workload, and source of funds with documents behind it.

5

A statement from the facility operator.

Sent to us directly by the data center, confirming capacity, confirming it is not the real end user, and agreeing to a later visit.

6

Eyes on site.

An independent inspector confirms the hardware is installed where the buyer said, with serial numbers and photographs. Pilot program.

See every check →

A file that stands up when someone asks.

We do not sell software, and we do not sell reassurance. We sell a compliance file that demonstrates reasonable diligence, structured to match the procedures the regulator has already published.

The file is yours. Keep it for the retention period, hand it to counsel, or produce it if asked.

  1. 01
    Scope statementWhat was checked, on what date, against which sources.
  2. 02
    Signed declarationsThe purchase-order declaration, the ownership and headquarters certification, and the GPU-ready statement where it applies.
  3. 03
    Screening record and ownership mapEvery party, every list, every result, with list versions and timestamps. Who ultimately controls the buyer, with sources.
  4. 04
    Transaction reviewEach question, the buyer's answer, the evidence behind it, and each published red flag tested.
  5. 05
    Facility operator statementAs received from the data center, not from the buyer.
  6. 06
    License positionFor an export: the requirements found on the case and the authorization you rely on, recorded as yours. For a sale inside the United States: your analysis of whether the hardware will be exported afterwards.
  7. 07
    Findings and recommendationProceed, proceed with conditions, or do not proceed. In plain language.
  8. 08
    Shipment recordWhat shipped, which serial numbers, under which filing, and what was confirmed at the site after delivery.

Built for the sellers without a compliance department.

The largest OEMs have in-house trade-compliance teams. Their distributors, resellers and the secondary-market brokers moving H100s, H200s and B200s between them carry exactly the same legal duties with none of that infrastructure.

If you are one of them, you are also the channel diversion actually runs through, and the one enforcement looks at first.

  • Distributors and VARswith an AI-infrastructure practice reselling OEM hardware.
  • Secondary-market brokerstrading restricted GPUs and servers, often to first-time counterparties.
  • Freight forwardersand logistics brokers handling controlled hardware.
  • Colocation operatorshosting third-party GPU deployments.

Modeled on the regulator's own guidance.

In May 2025, BIS published industry guidance on preventing diversion of advanced computing chips. It describes the red flags to look for, the questions to ask, and the diligence a seller is expected to perform.

We treat that document as the specification. Our questionnaire asks its questions. Our screening covers its lists. Our site protocol mirrors the structure of a published end-use check. When you hand our file to counsel, they will recognize the shape of it.

Read the methodology →

Twenty minutes to find out whether this fits.

Tell us how you screen buyers today and what a stalled deal costs you. We will show you a sample file and tell you exactly what we would do differently.

Book a call Request the sample file