Compliance · Sanctions & export control

Sanctions & Export Control

HEXATECH conducts every transaction in compliance with applicable sanctions and export-control regimes. The framework operates at every layer of every transaction — not only at Division II.

Sanctions & export control

Framework.

HEXATECH maintains a written Sanctions and Export-Control framework covering counterparty screening, item classification, end-use and end-user verification, transaction documentation, and post-delivery auditability. The framework applies across the three divisions, calibrated to the risk profile of each.

Regimes observed.

  • United Nations Security Council Consolidated Sanctions List
  • European Union Consolidated List of Financial Sanctions Targets
  • EU Dual-Use Regulation (EU) 2021/821 and EU Common Position 2008/944/CFSP
  • US Office of Foreign Assets Control (OFAC) sanctions programmes
  • US Bureau of Industry and Security (BIS) Entity / Denied Persons / Unverified Lists
  • US International Traffic in Arms Regulations (ITAR) — where US nexus exists
  • US Export Administration Regulations (EAR) — where US nexus exists
  • UK Office of Financial Sanctions Implementation (OFSI) Consolidated List
  • Partner-OEM jurisdiction national measures (Poland, Germany, Austria, Türkiye, Italy, others)
  • Republic of Kosovo export-control framework
  • Wassenaar Arrangement on conventional arms and dual-use goods and technologies (reference)

Transaction-lifecycle controls.

Five stages, applied on every relevant transaction:

  1. Lead qualification — preliminary sanctions and PEP screening of counterparty before substantive engagement.
  2. Specification and pre-offer — item classification under applicable export-control schedules.
  3. Offer and negotiation — confirmation of end-user and end-use; assessment of licence requirements.
  4. Contracting — End-User Certificates (EUCs) in the form required by the OEM jurisdiction; no EUC, no transaction.
  5. Delivery and post-delivery — delivery-milestone verification, any post-delivery reporting required by licence conditions.

Absolute boundaries.

⚠ Applied without exception

HEXATECH does not supply, broker, or integrate: items constituting weapons of mass destruction or their means of delivery; items controlled under NPT or CWC where not authorised; items prohibited by applicable sanctions or export-control regimes; items for end-uses associated with serious human-rights violations; offensive cyber capabilities. These exclusions apply irrespective of customer identity, commercial scale, or political pressure.

Governance.

Accountability vests in the Compliance Officer. Material transactions require Compliance Committee clearance. The framework is reviewed annually and upon material change in any regime.