Export Compliance Program Development for Emerging AI Hardware Company
Designed and implemented a comprehensive U.S. export compliance program for a rapidly growing AI infrastructure company that had been operating without a formal framework with products and services subject to the Export Administration Regulations. Conducted an initial self-assessment of all historical export transactions involving controlled GPU hardware, ultimately concluding that no violations had occurred under the applicable regulations. Developed a detailed end-user screening checklist incorporating BIS Red Flag Guidance, Know Your Customer standards, and industry-specific transactional indicators for advanced computing integrated circuits. Drafted enhanced End-Use Statement forms, registered the company with BIS's SNAP-R electronic licensing system, and advised on the purchase and deployment of a six-figure global trade compliance screening platform. Provided calibrated export controls training for executives and operational staff, and established escalation protocols for red flag resolution.
