Goods classification review
The company's own product catalogue checked against controlled and dual-use goods lists for items that may require a permit.
Export Control / Trade Compliance Review
Trade Sanctions & Export Control Review
An independent review of a company's Strategic Trade Act 2010 compliance, answering a different question from AML sanctions screening: not who you can transact with, but what goods you can export, broker or move through Malaysia.
Overview
Trade Sanctions & Export Control Review
What it is
An independent review of an exporter, manufacturer or trading company's Strategic Trade Act 2010 compliance: goods classification, permit and licensing status, end-user and end-use screening, and internal compliance programme documentation.
Why organisations need it
AML and sanctions screening gets most of the attention because it sits inside an established compliance function. Export control is easy to miss because it sits with trade, logistics or engineering teams who may not think of it as a compliance obligation at all. A product that looks purely commercial can still be a controlled or dual-use item under the Strategic Trade Act, and exporting, brokering or transiting it without the right permit is an offence regardless of intent.
Key features
What the engagement covers
Permit and licensing status review
Current permits checked against actual export, brokering and transit activity for gaps.
End-user and end-use screening review
Whether screening is actually performed before shipment, and how it is documented.
Internal compliance programme review
Policies, training and record-keeping checked against what a trade compliance programme is expected to show.
Distinction from AML sanctions screening
A short assessment of how this review's findings relate to, and do not duplicate, existing AML/CFT sanctions screening controls.
Remediation plan
Findings ranked by exposure, with owners and target dates.
Business value
What the business gets out of it
Answers a different question than AML screening
AML sanctions screening asks who you can transact with. This review asks what goods can cross a border.
Catches what trade teams miss
Classification gaps usually sit with engineering or logistics staff who do not see themselves as compliance owners.
Independent
A review, not a referral to a freight forwarder or licensing agent.
Ranked by exposure
Findings prioritised by the goods and markets actually involved.
Connects to the rest of the stack
Findings cross-referenced against existing AML/CFT sanctions screening where both are in scope.
How it works
How the engagement runs
01
Scoping
Product catalogue, export markets and current permits.
02
Classification review
Products checked against controlled and dual-use goods lists.
03
Permit and process review
Licensing status and screening process tested.
04
Documentation review
Compliance programme records against expected evidence.
05
Report
Findings, remediation plan and a management summary.
Deliverables
What you receive
Compliance review report
Findings ranked by exposure, with evidence.
Goods classification results
Which products may require a permit, and why.
Permit and licensing gap list
Current status against actual activity.
Screening process findings
What is documented and what is not.
Remediation plan
Owners, actions and target dates.
Who it is for
Who this is built for
Industries
Company sizes
Departments
Why Orbix
Why organisations choose Orbix
A governance approach, not a tool sale
We do not resell products, so nothing here is shaped by a vendor margin. The recommendation is whatever your risk and your budget actually justify, including telling you that you do not need the engagement yet.
Recommendations you can actually implement
Findings come with a sequence, an owner and a realistic effort estimate, sized to the team you have rather than the team a framework assumes. A report that cannot be acted on is an expense, not a control.
Consultants who have sat on your side of the table
Our people have carried the obligation internally, not only audited it. That shows up in what we consider proportionate, and in how much documentation we think you genuinely need.
Built for the Malaysian operating context
Work is grounded in Malaysian law and regulator expectation, from the PDPA and the Cyber Security Act 2024 to Bursa, BNM and SC requirements, rather than translated from a European or American template.
HRD Corp expertise where it applies
Where an engagement includes training, the training component is structured to be HRD Corp SBL-Khas claimable, which changes what the programme costs you in practice.
Questions
Questions we get asked
How is this different from AML sanctions screening?
Sanctions screening checks who you are transacting with against designated-person lists. This review checks what goods you are exporting, brokering or moving against controlled and dual-use goods lists under the Strategic Trade Act. They are separate regimes.
How do we know if our products are controlled?
That is the first step of the review: your actual product catalogue is checked against the controlled and dual-use goods lists, not assumed from a product description.
Do you apply for export permits on our behalf?
The review identifies where a permit is or should be in place. Applying for a specific permit is a separate engagement we can scope if needed.
Does this apply if we only sell domestically but import components?
It can still apply to brokering, transit or re-export activity. We confirm applicability during scoping.
How long does this take?
Typically three to five weeks, depending on the size of the product catalogue and the number of export markets.