Walk through the methodology with us.
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Methodology
Built on the guidance the regulator already published.
This page is written for your counsel and compliance staff. It explains what we check, against what, and why the file is structured the way it is.
Starting point
One specification, written by BIS.
In May 2025, the Bureau of Industry and Security published guidance for industry on preventing the diversion of advanced computing integrated circuits. Together with the long-standing "Know Your Customer" guidance and red-flag indicators in the Export Administration Regulations, it sets out what a seller is expected to do before and around a transaction.
ClearEndUse's process is designed so that each element of a file corresponds to an element of that guidance. We do not claim any endorsement or recognition from BIS. We claim that a reviewer familiar with the guidance will find our file organised in the way they expect.
Buyer vetting
What we check.
1 · PARTY SCREENING
Every entity and person named.
Screened against the BIS Entity List, Denied Persons List, Unverified List and Military End-User List; OFAC Specially Designated Nationals and consolidated sanctions lists; and allied lists as applicable. Screening is name, alias and address based. List versions and timestamps are recorded in the file.
2 · BENEFICIAL OWNERSHIP
Traced to controlling natural persons.
Through corporate registries and filings. Where ownership passes through jurisdictions with limited transparency, that is stated as a finding rather than left silent. We apply the 50 percent rule where relevant sanctions programmes require it.
3 · END USE AND END USER
Tested for plausibility.
Against the buyer's public footprint, size and sector; the stated installation facility's address, existence and capacity; consistency between quantity ordered and stated purpose; and prior transaction history where available.
4 · RED-FLAG REVIEW
Each indicator answered, with evidence.
Reluctance to provide end-use information, a freight forwarder as final destination, shipping routes inconsistent with the destination, payment terms inconsistent with the buyer's profile, and the rest. A red flag raised is not a conclusion. It is a question we then resolve or report as unresolved.
5 · ATTESTATION
Part of the file, not a substitute for it.
The buyer signs a regulatory attestation covering end use, end user, destination and re-export.
6 · FINDINGS
One of three recommendations.
Proceed, proceed with stated conditions, or do not proceed. Where a licence may be required, we say so. We do not make licence determinations.
Installation verification
What we observe.
Our site protocol mirrors the structure of a published end-use check: identity of the inspector, identity of the site contact, physical presence of the items, reconciliation to documented records, and observations on use.
- Facility identity and address as verified on site
- Racks present, with serial numbers matched line by line to the manifest
- Photographs with device timestamps and, where permitted, location metadata
- Observed power and network status
- Chain-of-custody documents held by the site, as shown
The inspector does not access, copy or retain configuration data, workloads or logs. This is deliberate. It protects the operator and keeps the report to what an independent observer can attest.
Independence
No stake in the outcome.
ClearEndUse is paid by the seller and has no financial interest in whether a transaction proceeds. Inspectors are contracted, not employed by any party to the transaction, and confirm in writing that they have no relationship with the buyer or the site.
Limits
What a file can and cannot say.
- A file documents diligence performed on a stated date against stated sources. Lists change. Ownership changes.
- A site report documents observations on a stated date. Hardware can move afterwards.
- Neither is a legal opinion, licence determination or guarantee of compliance.
- ClearEndUse's liability under engagement terms is capped at fees paid for the engagement.