Walk through the methodology with us.
Bring your counsel. We will go through the file section by section and take every question.
Built on the guidance the regulator already published.
For your counsel and compliance staff. What we check, against what, and why the file looks the way it does.
Three documents from BIS.
- The diversion guidance, May 2025. The red flags to look for and the diligence steps to take before selling advanced computing chips. Our questionnaire asks its questions, in its order.
- The headquarters guidance, 31 May 2026. A license is needed when the buyer, or the buyer's ultimate parent, is headquartered in China or another arms-embargoed country, wherever the buyer sits. Our file states that finding on its own line.
- The 50 percent rule, September 2025. A company owned 50 percent or more by listed parties counts as listed, and the seller must be able to say how it knows the percentage. Our file records every percentage with the document behind it.
We claim no endorsement from BIS. We claim that a reviewer who knows these documents will find each item in our file where they expect it.
Eight checks. Each a separate source of evidence.
A list-screening tool and a signed form tell you a name is not on a list. These tell you who the buyer is, where the hardware is going, and whether the story holds.
1 · PER-ORDER DECLARATION
The buyer signs, on every order.
What the hardware is for, who will use it, where it will be installed, no weapons or sanctioned parties, and consent to an inspection after delivery.
2 · OWNERSHIP AND HEADQUARTERS
Who owns the buyer, and where they sit.
The chain to the ultimate parent, each level checked against the public record. The percentage at every level, with its source. A clear yes or no on the headquarters test.
3 · GPU-READY SYSTEMS
Servers sold without chips.
Will accelerators be added later, and which? The buyer signs the answer. Where it raises a license question, we say so and refer you to counsel.
4 · DOES THE DEAL MAKE SENSE
The story, tested.
Is the ship-to the real destination? Can the facility power this many servers? Does the quantity fit the workload? Where does the money come from? Who can reach the systems remotely?
5 · FACILITY OPERATOR STATEMENT
From someone with no stake in the sale.
The data center confirms to us directly that the space and power exist, that it is not the real end user, and that it will let an inspector in.
6 · SCREENING
Every company and person named.
Against the BIS, OFAC and allied lists, by name, alias and address. List versions and timestamps go in the file.
7 · RED FLAGS
Each one answered.
Every published indicator is tested. A flag raised is a question, not a conclusion: we ask, record the answer, and say whether it is resolved.
8 · FINDINGS AND LICENSE POSITION
Proceed, proceed with conditions, or do not proceed.
In plain language, with the evidence and the date. Your license position is recorded as yours and tested against the facts. We do not make license determinations.
What the inspector sees.
The same structure as a published end-use check: who inspected, who was there, what was present, and whether it matches the paperwork.
- The racks are at the stated address, serial numbers reconciled against the manifest
- The hall, floor and power match what the buyer and the operator said
- Power, cooling and network can run this deployment
- Timestamped photographs of all of it
- Who was on site, by name and role
The inspector never touches configuration data, workloads or logs. That protects the operator and keeps the report to what an outsider can attest.
Installation verification is a pilot program with limited capacity. See the on-site checks →
No stake in the outcome.
The seller pays a fixed fee. It does not change with the result. Inspectors are contracted, not employed by anyone in the deal, and confirm in writing that they have no relationship with the buyer or the site.
What a file cannot do.
- It records what was true on a stated date. Lists change. Ownership changes. Hardware moves.
- It is not a legal opinion, a license determination, or a guarantee of compliance.
- Our liability is capped at the fees paid for the engagement.