Policy Overview
Aevum Zenth maintains a zero-tolerance stance regarding violations of national and international export control regulations. All employees, contractors, and third-party partners engaged in the development, transfer, or shipment of controlled items must comply with this policy without exception.
This policy applies to all physical exports, reexports, deemed exports, and electronic transmissions of controlled technical data, software, and source code originating from or controlled by any Aevum Zenth entity.
Applicable Regulatory Frameworks
Our global operations require adherence to multiple jurisdictional regimes. Primary frameworks include:
| Regulation | Jurisdiction | Key Focus | Primary Authority |
|---|---|---|---|
| EAR Export Administration Regulations | United States | Dual-use technologies, software, encryption | BIS / Dept. of Commerce |
| ITAR International Traffic in Arms Regulations | United States | Defense articles, military specifications, USML | DDTC / Dept. of State |
| EU Dual-Use Regulation 2021/821 | European Union | Dual-use goods, technical data, brokering | European Commission |
| Wassenaar Arrangement | Multilateral | Conventional arms & dual-use goods transparency | Participating States |
| ARTEMIS / MTCR / NSG | Multilateral | Missile tech, nuclear exports, sanctions alignment | Participating States |
US-origin controlled items retain US jurisdiction regardless of manufacturing location. Subsidiaries operating outside the United States must still comply with EAR/ITAR where US-origin content exceeds de minimis thresholds or involves direct product rules.
Classification & Screening Procedures
Accurate classification is the foundation of export compliance. All controlled items must be assigned the correct classification code prior to any transfer.
- ECCN Determination: Dual-use items must be matched against the Commerce Control List (CCL) to identify the correct Export Control Classification Number.
- USML Categorization: Defense articles and related services must be mapped to the United States Munitions List.
- Country Screening: Destination countries must be cross-referenced against BIS Entity List, Treasury SDN List, and UN/EU sanctions regimes.
- End-User Verification: Buyers, consignees, and beneficial owners must undergo KYC (Know Your Customer) and due diligence screening.
Transfers to denied parties, embargoed destinations, or entities with known WMD proliferation ties are strictly prohibited. Unauthorized disclosures of controlled technical data to foreign nationals on-site constitute deemed export violations.
Licensing & Approval Process
Most controlled transfers require prior authorization. License requirements are determined by the combination of item classification, destination country, end-use, and end-user.
| Transaction Type | License Requirement | Processing Time |
|---|---|---|
| License Exception (e.g., LVS, APP, CIV) | Self-classification & documentation | Immediate (with internal approval) |
| License Application (Standard) | Submitted to BIS/DDTC via SNAP-R or NLR | 30–90 days |
| Short-Term License (SSL) / Multiple License Report (MLR) | Recurring shipments to same destination | Annual renewal |
| Deemed Export Training / Access Control | University/Contractor personnel screening | Pre-access mandatory |
All license applications must be routed through the Global Export Controls Office (GECO). Divisional leadership must not approve shipments without documented GECO clearance.
Training, Reporting & Recordkeeping
Continuous compliance requires structured education and transparent incident reporting.
- Mandatory Training: All personnel handling controlled items must complete role-based export controls certification annually.
- Record Retention: Export documentation, license approvals, screening records, and correspondence must be retained for minimum of 5 years.
- Incident Reporting: Suspected violations, misclassifications, or denied shipments must be reported within 24 hours via the internal compliance portal.
- Whistleblower Protection: Aevum Zenth strictly prohibits retaliation against employees who report compliance concerns in good faith.
Global Export Controls Office (GECO)
For classification assistance, license submissions, screening reviews, or policy clarifications, contact your regional compliance liaison or the central GECO team.
export.controls@aevumzenth.com | Internal Extension: 8042 | Secure Portal: compliance.aevumzenth.internal