3
Stacked control layers
19
Markets served
5
Service lines
100%
Operator-side
02The operating reality
02
Operators in this sector move goods, technology and knowledge that a state controls on purpose. The activity spans several roles, and each one is examined differently:
- Defence manufacturers and integrators producing controlled goods, components or platforms.
- Dual-use exporters shipping items with a civilian purpose and a military application: electronics, optics, machine tools, chemicals, navigation, encryption.
- Procurement intermediaries, agents and brokers arranging supply between a producer and a foreign end user.
- Logistics, freight-forwarding and financing parties touching a controlled consignment along the chain.
The load is threefold, and the three layers stack:
- Export-control classification: every item screened against a national control list before it moves. Get the classification wrong and the licence you hold does not cover the shipment you sent.
- End-user and end-use diligence: the buyer on the invoice is rarely the whole story. Diversion, transhipment, front companies and undeclared re-export turn a lawful sale into a sanctions breach.
- Sanctions and financial-crime screening: counterparties, beneficial owners, vessels, aircraft and correspondent banks all clear watchlist screening, and the payments trace cleanly.
This is where AML, sanctions and export control stop being three separate disciplines and become one file. Most operators run them in three teams that do not reconcile. That gap is exactly what an examiner walks into.
R/01
Export-control classification
Every item assessed against the current national control list before it moves.
R/02
End-user and end-use diligence
The buyer on the invoice is rarely the whole story.
R/03
Sanctions at every party
Counterparties, owners, vessels, aircraft and banks, against current lists.
R/04
Diversion and transhipment
The failure modes that turn a lawful sale into a sanctions breach.
R/05
Payments that trace
Defence flows attract enhanced scrutiny from every bank that touches them.
R/06
One file, not three teams
AML, sanctions and export control reconciled into a single record.
03The test
What an examiner tests for
A national export-control authority, a customs directorate or a correspondent bank does not ask whether you hold a permit. They assume you do. They test whether the programme behind it works. The test underneath is always the same: not "did you have a policy" but "did the policy run, and can you prove it ran". A binder is not a programme.
Test
Classification integrity: item by item, assessed against the current national control list, with a sign-off. A live process, not a one-time spreadsheet.
Test
End-user verification that holds: end-use certificates on file, corroborated and re-checked, with evidence you screened for diversion and transhipment risk, not just collected a signature.
Test
Beneficial-ownership resolution: the real party behind the intermediary, the broker and the consignee, resolved to a natural person and screened.
Test
Sanctions screening depth: names, aliases, vessels, aircraft, addresses and ownership-threshold and control-test logic, screened against current lists, with the hits investigated and dispositioned.
Test
Red-flag escalation: a documented path from a warehouse or finance-desk concern to a filed suspicion report, with the decision trail intact.
Test
Record-keeping and reconstruction: the whole transaction, from enquiry to shipment to payment, reconstructable from the file years later. That is what a post-incident review demands.
04The build
We are operator-side only. We sell no screening software, broker no deals and take no commission on any shipment. We are the reviewer, not the seller. Across our five service lines, here is what that means for a defence or dual-use operator.
S/01
Licensing and new-regime programme build
The programme behind the permit.
When you are entering a market or standing up under a new export-control regime, we build the programme behind the permit: the control-list classification process, the end-user diligence framework, the sanctions-screening model, the escalation path and the record architecture. A costed plan within 48 hours, fixed scope, fixed fee, no hourly billing.
S/02
Remediation
The programme after the finding.
After a denied shipment, a customs hold, a regulator finding or a de-risking notice from your bank, we go in, find why the programme failed, rebuild the broken control and evidence the fix. We write the remediation so it answers the specific finding, not a generic template.
S/03
Outsourced and bridge MLRO, plus a managed financial-intelligence function
The programme as a live function.
Where the regime requires a compliance officer or an MLRO and you do not yet have the seniority in seat, we run it: reviewing screening alerts, dispositioning red flags, filing suspicion reports and holding the line with your correspondent banks, as a bridge or on an ongoing managed basis.
S/04
Independent AML audit
The reviewer, not the seller.
The independent review the framework expects, and the one your bank increasingly demands before it will keep the account. We test the programme against the current requirements, evidence what works, name what does not and hand you a defensible report.
S/05
Sanctions, export-control and integrity due diligence, including the FATF Travel Rule
The core of this sector.
End-to-end end-user and end-use diligence, deep counterparty and beneficial-ownership resolution, sanctions and export-control screening across counterparties, vessels and routes, transhipment and diversion analysis, and Travel Rule handling where a payment leg involves virtual assets.
05Coverage
Served across all 19 markets
This sector is served across all 19 markets we cover, Frontier and Gulf, with the same programme discipline in each. Export-control authority and enforcement posture differ market to market. We build to the body that actually holds the mandate where you operate. A few concrete anchors from our regulator map:
Saudi Arabia
The General Authority for Military Industries (GAMI) governs the military-industries sector.
UAE
The Executive Office for Control and Non-Proliferation (EOCN), with military items licensed by the Ministry of Defence.
Turkey
The Ministry of National Defence General Directorate of Strategic Trade Controls and the Ministry of Trade handle strategic and dual-use export licensing, alongside the Presidency of Defence Industries (SSB).
Pakistan
The Strategic Export Control Division (SECDIV) at the Ministry of Foreign Affairs.
South Africa
The National Conventional Arms Control Committee (NCACC) and the Council for the Non-Proliferation of Weapons of Mass Destruction.
Kazakhstan
The Committee for Industrial Development of the Ministry of Industry and Construction administers export-control and specific-goods licensing.
Nigeria
The National Centre for the Control of Small Arms and Light Weapons, with the Federal Ministry of Defence and DICON.
Egypt
The General Organization for Export and Import Control (GOEIC) and the Ministry of Defence and Military Production.
Even coverage. 19 markets. One programme, calibrated to the body that holds the mandate.
06The honest line
Where the activity is restricted or state-controlled
Defence and dual-use activity is not open to private operators everywhere on equal terms. Where the activity is restricted, state-controlled or not yet in force for private operators, we say so plainly and scope the engagement to what is actually permitted, rather than promise a programme the regime does not allow.
Hard line
We do not help anyone move controlled goods around a control that exists for a reason.
Narrow perimeters
In several markets the control body is a defence-ministry procurement function, a customs directorate or an interior-ministry arms-permit authority, narrowing who may lawfully broker, export or intermediate.
Framework forming
Kenya: a dedicated Strategic Goods Control Committee is proposed under the Strategic Goods Control Bill and is not yet operational.
We verify first
The control regime and the perimeter are checked against the named body before we scope.
07Market x sector
The sector page tells you what we build. The market pages tell you who examines it. The top defence and dual-use combinations, then every market we serve:
Defence inSaudi Arabia
Defence inUAE
Defence inTurkey
Defence inPakistan
Defence inSouth Africa
Defence inKazakhstan
AzerbaijanState Service for Export Control and Protection of Military Secrets under the Cabinet of Ministers.
BahrainMinistry of Interior, Customs Affairs.
EgyptGOEIC and the Ministry of Defence and Military Production.
GeorgiaMinistry of Defence Standing Committee on Military-Technical Matters, permits issued by the Revenue Service.
GhanaMinistry of the Interior arms and ammunition permits, with GRA Customs, the Ghana Standards Authority and the EPA at export-import.
JordanMinistry of Industry, Trade and Supply export licensing, with Jordan Customs enforcement.
KazakhstanCommittee for Industrial Development of the Ministry of Industry and Construction.
KenyaStrategic Goods Control Committee proposed under the Strategic Goods Control Bill; not yet operational.
KuwaitMinistry of Defense Foreign Procurement Sector, Ministry of Commerce and Industry licensing, Ministry of Interior arms permits, customs enforcement at the border.
KyrgyzstanMinistry of Economy and Commerce as the authorised export-control body, supported by the Center on Export Control.
NigeriaNCCSALW under the Office of the National Security Adviser, with the Federal Ministry of Defence and DICON.
OmanRoyal Oman Police Directorate General of Customs and MOCIIP.
PakistanStrategic Export Control Division (SECDIV) at the Ministry of Foreign Affairs.
QatarMinistry of Interior arms licensing and Ministry of Defence procurement, with the General Authority of Customs.
Saudi ArabiaGeneral Authority for Military Industries (GAMI).
South AfricaNCACC and the Council for the Non-Proliferation of Weapons of Mass Destruction.
TurkeyMinistry of National Defence General Directorate of Strategic Trade Controls and the Ministry of Trade, alongside the SSB.
United Arab EmiratesExecutive Office for Control and Non-Proliferation (EOCN), with military items licensed by the Ministry of Defence.
UzbekistanMinistry of Investment, Industry and Trade.
08Proof
PartnershipLocal partnersSigned partnership with an AIFC firm licensed by the AFSA, extending on-the-ground reach in the region.Partners →
Published workBriefing seriesThe Black Sea briefing series, read by operators and regulators across these markets, with independent Kazakh press pickups.Insights →
CredentialsCAMS / ICAPractitioner-led: CAMS and ICA credentialed, senior-only, no junior hand-off.The firm →
Fresh proofVerifiable todayIn place of client references we point to the live briefing feed, the signed partnership and the earned press it has drawn. No published client names, no invented case studies.The record →
Bring us the file that worries you.
We assess the exposure, scope the work and return a costed plan within 48 hours. Fixed scope. Fixed fee. No hourly billing.