Trade Compliance Review Report
Trade Summary

Trade ID: TRD-4591  
Counterparty: EuraTech Global Holdings Ltd.  
Commodity: Semiconductor components (dual-use item)  
Transaction Value: $4,250,000  
Route: Hamburg, Germany → Odessa, Ukraine (Maritime)  
Date: 2025-11-08  
Incoterm: CIF  
Risk Score: 82 (High)  
Internal Risk Rating: Elevated  


Risk Detection Summary
1. Sanctions Exposure

Flag: Partial match found with “EuraTech Components GmbH,” a subsidiary under OFAC observation.  
Source: OFAC Watchlist + EU Sanctions List (2025-11-05).  
Severity: High  
Impact: Potential regulatory breach if entity is later confirmed as sanctioned.  
Action: Verify corporate structure and perform enhanced due diligence.

2. Dual-Use Commodity Concern

Flag: Semiconductor components are classified as dual-use under EC 2025-09 bulletin.  
Source: EU Regulatory Bulletin (EC 2025-09).  
Severity: High  
Impact: Export may require special licensing and end-user verification.  
Action: Obtain export license and end-use certification prior to shipment.

3. Route and Geopolitical Exposure

Flag: Destination near embargoed region (Ukraine conflict zone).  
Source: Customs alert and risk routing database.  
Severity: Medium  
Impact: Increased scrutiny from customs; possible delay or denial.  
Action: Review transport documentation and verify carrier compliance.

4. Documentation Deficiency

Flag: End-use certificate missing; previous cases show similar pattern.  
Source: Internal audit note and compliance history.  
Severity: Medium  
Impact: Non-compliance with export control documentation requirements.  
Action: Request missing certificate and update compliance checklist.

5. Historical Compliance Pattern

Flag: Prior documentation and filing violations (COM-3294, COM-3367).  
Severity: Low (Historical)  
Impact: Recurrence could elevate compliance risk category.  
Action: Monitor corrective actions and verify completion logs.


AI-Generated Compliance Assessment
Materiality Level: High

Urgency Level: Immediate escalation required

Primary Risks: Sanctions exposure, missing end-use documentation, dual-use export compliance

Secondary Risks: Trade route sensitivity, repeated minor documentation lapses  

Recommended Remediation Actions

Conduct enhanced due diligence on EuraTech’s ownership and subsidiaries.  
Obtain end-use certificate and validate the buyer’s export license eligibility.  
Confirm license requirements under EC 2025-09 before shipment.  
Escalate the trade for manual compliance review and temporary hold until verification.  
Auto-generate regulatory disclosure draft for internal approval (EU/OFAC compliance).  


Auto-Generated Audit Documentation

Consolidated Data Sources: Sanctions lists, OFAC watchlist, internal records, and transaction details.  
Detected Risk Flags: 5 total (2 High, 2 Medium, 1 Low).  
Supporting Evidence: Linked invoices, due diligence records, and prior compliance cases.  
Action Log (AI-Generated): Drafted remediation memo and assigned compliance officer for review.  


Final Decision (AI Recommendation)

Status: Hold for Compliance Review

Reason: High-risk trade partner and missing mandatory documentation.

Next Review Date: 2025-11-12

Responsible Officer: Compliance Lead – Global Trade