Export Controls and Sanctions

How are export controls and sanctions relevant for my company?

Export controls, sanctions and embargoes are not new. However, trade globalisation, geopolitical tension, terrorism and international political developments have resulted in increased enforcement by the national authorities in this area. All these topics were raised by respondents in PwC’s Global Crisis Survey 2021

As the global landscape grows more complex and connected, companies are at threat of a sudden shock. It could be a sanctions violation, a shipment of a controlled item that accidentally went through or perhaps a data breach disclosing export controlled data. With shock also comes opportunity. An incident managed well allows an organisation to take on riskier opportunities with the knowledge that future threats will be spotted and addressed quickly. As each client has different challenges, we can help you prepare, respond and emerge stronger from crises and other unplanned events.

A selection of the services we can provide:


Continuously monitoring internal activities such as client acceptance, sales orders, etc., and enhancing this data with external sources has proven to be key in staying on top of your compliance position. For this purpose we have developed Continuous Monitoring Platform (CMP). CMP offers a wide variety of services ranging from restricted party screening and sanction screening to screening your item or technology against for instance the EU dual use list or US Commerce Control List.

Training & Awareness

People in your organization should know what they are allowed to do and what they are not allowed to do in respect of sanctions and export controls restrictions. Behaviour is key. Compliance is your license to operate. We can assist in providing tailor made training through train-the-trainer programs. Furthermore, we have developed the Game of Trade and the Game of Sanctions which are so called gamifications of real live events in the areas of trade and export controls. The Game of Sanctions is an immersive game-based platform which simulates the effects of trading in controlled goods and with potentially sanctioned parties.

The Game of Sanctions applies the ‘gamification’ philosophy, making it easy to learn and attractive to play. This makes the challenging rules on export controls accessible to non-specialized persons. The Game of Sanctions can be the conversation starter for a company to review and discuss the internal processes on export controls.

Crisis Management

The world as we know it today, is an uncertain place. Preventing a crisis is of course the ultimate goal, but it is nevertheless important to be prepared when a crisis hits. As PwC’s Global Crisis Survey 2021 shows, CEOs from companies all over the world recognize various potential crises, ranging from having operational to reputational effect. 

When your company faces a crisis, e.g. when sanctions are violated and your company is being scrutinized by US authorities, we can assist you in responding to and recovering from such a crisis. Even better, we can assist you in preparing for a crisis through one of our customized crisis simulations.

Automated Classification

When it comes to ECCN classification, manual processes are cumbersome and systemic. Many classification processes in organizations are currently manual, whereas classification regulations and sanctions are constantly changing. Systems and data are siloed, though supervisors are becoming more and more tech savvy and expect companies to do the same thereby relying on (their) data. For this purpose, we have developed an automated classification solution. Using the company's product data and AI technologies, the solution will be able to classify the products (parts, assemblies, final products and technology) with a correct export controls classification number (ECCN).

Our team

Our team includes subject matter experts with a background in investigations, compliance and customs, and have extensive knowledge and experience in sanctions & export controls matters. Our team is active globally, which includes knowledge on export controls in over 130 countries. We work closely together to ensure that the required aspects are covered.

We have vast experience in investigating potential non-compliance, such as (alleged) violations of sanctions and/or export of controlled items. We work with our clients to not only recover from current crises, but also enhance their ability to learn and improve after unplanned events. 

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Claudia Buysing Damsté

Claudia Buysing Damsté

Partner, PwC Netherlands

Tel: +31 (0)65 103 04 63

Sylvie Bleker-van Eyk

Sylvie Bleker-van Eyk

Senior Director, PwC Netherlands

Tel: +31 (0)68 380 20 37

Pascal Huizinga

Pascal Huizinga

Senior Manager, PwC Netherlands

Tel: +31 (0)61 201 17 20

Mieke Kuijken

Mieke Kuijken

Senior Manager, PwC Netherlands

Tel: +31 (0)61 261 74 66