What’s Getting Harder in Compliance: How Dual‑Use Goods and Export Controls Are Changing

A new era of export scrutiny

Export compliance has never been simple. But the world has changed and so has compliance. The war in Ukraine, conflicts across the Middle East and intensifying U.S.-China competition have triggered waves of new sanctions, expanded dual-use definitions and tighter export controls.

The pace of regulatory change has been relentless. Since Ukraine, the EU has imposed 19 sanctions packages blacklisting over 2,700 individuals and entities¹, while the US Bureau of Industry and Security (BIS) has added hundreds of names to its Entity List and significantly updated its Export Administration Regulations (EAR)², citing concerns about China's military modernisation, Russian sanctions evasion and growing tensions with Iran. The UK, Australia and others have followed suit with new controls of their own.

For freight forwarders, the impact is cumulative. Every change means a broader set of parties to screen, more destinations to validate and more goods demanding classification against control lists across multiple jurisdictions. 

Dual‑use goods: from edge cases to everyday items

For decades, export controls targeted a relatively narrow set of high‑risk items. Military items were clearly regulated, dual‑use lists were manageable and multilateral agreements such as the Wassenaar Arrangement kept member states broadly aligned. Most commercial cargo cleared predictably, without significant regulatory intervention.

That is no longer the case. Since 2022, Russia has used its veto to block updates to the Wassenaar Arrangement, particularly around emerging technologies. In response, many member states have established their own restrictions outside the traditional multilateral framework, an approach known as ‘Wassenaar minus one’. The European Union has gone further, introducing a new “500 series” of EU-only export controls, marking the first time it had regulated dual‑use items without multilateral agreement.³ Advanced semiconductors, quantum computing components, as well as rare minerals and precursor materials are all now subject to new regulations.

Importantly, this shift is not limited to leading‑edge technologies. Electronics and industrial equipment that once cleared as everyday items are now tripping controls, not because the finished goods themselves are inherently sensitive, but because they contain components that appear on one or more control lists.

Emerging and converging technologies blur definitions

Even if control lists had stayed the same, modern technologies are emerging and converging in ways that make historical classifications unreliable.

Consider the modern mobile phone. These devices pack together advanced processors, motion sensors and communications hardware, any of which may be subject to controls depending on its specifications. A single item can then fall across multiple classification categories simultaneously. Determining the right one means analyzing not just what the item is, but what is inside it and what it will be used for. Software and firmware add another layer. Hardware unrestricted in its base form can become controlled the moment it is loaded with firmware enabling military applications.

The deeper danger with converging technologies is that advanced components are now so widely embedded in consumer goods that they can be extracted and repurposed for military systems. Russian weapons systems recovered in Ukraine have been found to contain chips from leading U.S. manufacturers as well as other parts traced back to household appliances such as dishwashers, washing machines and air-conditioning units.⁴

Different regions define goods differently

How goods are classified also varies by jurisdiction. The same item can fall into different control categories depending on which country's rules apply, each with its own technical thresholds and definitions.

For freight forwarders, this means a single shipment can require assessment against multiple overlapping frameworks simultaneously. A consignment moving from the U.S. to Singapore, for example, may need to satisfy U.S. Export Administration Regulations (EAR) at origin, destination‑country import controls on arrival, and the EU Dual‑Use Regulation if the goods transit through Europe.

Regulators are well aware that transshipment through countries with lighter controls is a common tactic for routing goods to sanctioned end users, often aided by opaque business ownership structures that make the end user difficult to identify. They have responded by expanding their reach. The EU's 16th sanctions package imposed restrictions on 53 companies suspected of supporting Russia's military-industrial complex, with almost two-thirds of these companies based outside Russia.⁵ For compliance teams, the challenge is not just screening against a single control list; it is reconciling multiple overlapping frameworks simultaneously, across every party and transit point.

What this means for freight forwarders

Customs and trade authorities all around the world are increasingly treating freight forwarders as active compliance gatekeepers, not just cargo handlers. When a shipment is linked to a violation, the forwarders will be named in the documents, and regulators will ask not only what the forwarder knew, but also if they exercised due diligence.

The difficulty is that freight forwarders carry this obligation with less information than almost anyone else in the chain. Unlike manufacturers, they have limited product knowledge. Unlike exporters, they have no relationship with the end user. They rely entirely on what the customer provides: a product description, an HS code, perhaps an end-use statement. This information is typically too vague –sometimes because of oversight, sometimes because the exporter genuinely doesn't understand the regulatory implications of what they're shipping.

Consider a consignment listed as 'thermal imaging cameras.' Whether the units operate below 9Hz (in which case no export license is typically required), or above (which could place them under ECCN 6A003 or even ITAR defense article controls), depends on frame rate and detector resolution.⁶ Answering that question means pulling manufacturer specifications, cross-referencing technical parameters against control lists and making a judgment call. That is the work involved in a single shipment. Multiply it across hundreds of containers a week, each carrying its own ambiguous descriptions, suspect parties or uncertain destinations, and the cumulative burden on compliance teams becomes clear.

The volume of trade subject to this kind of scrutiny is also growing. UNCTAD’s latest figures show manufacturing trade grew 10% over the past year and electronics 14%⁷ – the two categories under the most dual‑use scrutiny. Together, rising volumes and ever-evolving compliance obligations are pushing even capable teams toward an impossible choice: move fast and absorb risk, or flag conservatively and create bottlenecks. Neither is sustainable, but it is a challenge that new technologies, and AI-assisted screening tools in particular, are well suited to solve.

This article is the first in a three-part series on the modern demands of export compliance. ComplianceWise helps freight forwarders screen goods, parties and destinations against export control lists – now featuring purpose-built AI agents to research and classify commodities automatically. Visit ComplianceWise to learn more.

Citations

1. Council of the European Union. "Sanctions: How and When the EU Adopts Restrictive Measures." Consilium. https://www.consilium.europa.eu/en/policies/sanctions-against-russia/. Accessed 20 Feb. 2026.

2. Bureau of Industry and Security. "Commerce Further Restricts China's Artificial Intelligence and Advanced Computing Capabilities." BIS.gov, 2025. https://www.bis.gov/press-release/commerce-further-restricts-chinas-artificial-intelligence-advanced-computing-capabilities. Accessed 20 Feb. 2026.

3. European Commission. "2025 Update of the EU Control List of Dual-Use Items." Policy.trade.ec.europa.eu, 8 Sept. 2025. https://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08_en. Accessed 20 Feb. 2026.

4. United States Senate Permanent Subcommittee on Investigations. The U.S. Technology Fueling Russia's War in Ukraine. 10 Sept. 2024. https://www.hsgac.senate.gov/wp-content/uploads/09.10.2024-Majority-Staff-Report-The-U.S.-Technology-Fueling-Russias-War-in-Ukraine.pdf. Accessed 20 Feb. 2026.

5. Council of the European Union. "Three Years of Russia's Full-Scale Invasion and War of Aggression Against Ukraine: EU Adopts Its 16th Package of Economic and Individual Measures." Consilium, 24 Feb. 2025. https://www.consilium.europa.eu/en/press/press-releases/2025/02/24/three-years-of-russia-s-full-scale-invasion-and-war-of-aggression-against-ukraine-eu-adopts-its-16th-package-of-economic-and-individual-measures/. Accessed 20 Feb. 2026.

6. Bureau of Industry and Security. "Revision of License Requirements of Certain Cameras, Systems, or Related Components." Federal Register, 89 FR 13862, 23 Feb. 2024. https://www.federalregister.gov/documents/2024/02/23/2024-03661/revision-of-license-requirements-of-certain-cameras-systems-or-related-components. Accessed 20 Feb. 2026.

7. UN Trade and Development (UNCTAD). Global Trade Update, December 2025. https://unctad.org/publication/global-trade-update-december-2025-global-trade-poised-record-breaking-2025-flows. Accessed 20 Feb. 2026.