Human Rights Watch

Use the steps below to review this page. Verify the complete official text before making a decision. Seek qualified advice when needed.

1. Define the decision

   State the exact decision, owner, deadline, trade direction and required evidence. Do this before you search.

2. Identify every party

   Confirm each legal name and alias. Check registration, ownership, control, intermediaries, carriers, banks and beneficial owners.

3. Describe the item

   Record the item’s function, operating principle, material, model and performance. Include software, technology, accessories and decisive parameters.

4. Check classification

   Treat customs and export-control classification as separate tasks. Keep the facts, assumptions and reasoning for each result.

5. Map the route

   Confirm origin, departure, destination and transit points. Include re-export, remote access, technology transfer and each delivery path.

6. Verify end use

   Identify the stated purpose and real operating environment. Check integration, sensitive sectors, military links and prohibited uses.

7. Verify end users

   Check the purchaser, consignee, end user, operator and parent company. Identify anyone who can redirect or control the item.

8. Read the complete source

   Treat a search result as a lead. Read the official scope, definitions, notes, exclusions, annexes and licence conditions.

9. Check current measures

   Use the version effective on the transaction date. Review later notices, temporary controls, destination measures and policy changes.

10. Test exceptions carefully

    Prove every condition before using an exception or exemption. Apply the same rule to licence facilitation and general authorisations.

11. Resolve contradictions

    Pause when names, codes, documents, routes, prices or explanations conflict. Obtain evidence instead of filling gaps with assumptions.

12. Escalate uncertainty

    Send unresolved questions to the compliance owner or a qualified adviser. This includes classification, ownership, use, destination and licensing.

13. Keep an audit trail

    Keep source links, files, checksums, screenshots, search terms and results. Record the reviewer, approvals and final reasoning.

14. Schedule re-checks

    Set a new review date for open transactions. Re-check changing parties, destinations, specifications, official lists and licences.