See the file for one of your buyers.
Bring a real counterparty, anonymized if you prefer. We will show you what we would check and what the file would say.
A signed, checked, documented file on every buyer before you ship.
No owner at 50% or more. Headquarters test not met; position recorded for counsel.
Listed-party subscriber excluded from these systems. Re-screen on or after 10 Nov 2026.
We read it and fill in the buyer, the items and the parties for you to confirm. Five minutes.
A declaration on the order, an ownership and headquarters certification, and a questionnaire on the deal. A buyer who will not complete it has told you something.
Space and power exist. The operator is not the real end user. An inspector will be let in later. The statement never passes through the buyer.
Anything that needs judgment is reviewed by a person first.
The diligence the largest manufacturers run in-house. Here it is, line by line.
A signed buyer declaration, tied to the PO, before you ship.
Where the buyer is headquartered can matter as much as where the hardware ships.
A server without accelerators can become a controlled item once someone installs them.
Most diversion cases look fine on paper. These questions test the story.
The one document in the file signed by someone with no stake in the sale.
After delivery, an independent inspector confirms the hardware is where the buyer said, with serial numbers and photographs. Pilot program, limited capacity. See the on-site checks →
Every check goes in the file as a question, an answer, the evidence and the date. A refusal to answer goes in too.
Everything a reviewer would ask for, where they expect it.
Request the sample file →A record of diligence on a stated date against stated sources. Not a license determination, not a legal opinion, not a guarantee. Where a license may be needed, we say so and refer you to counsel.
Bring a real counterparty, anonymized if you prefer. We will show you what we would check and what the file would say.