“What’s the right response when an incident occurs?”

Incidents in export control rarely arrive with fanfare. They tend to surface quietly — a detail that doesn’t look right, a shipment that raises a question, a moment where something feels off. And in those situations, the real challenge isn’t the incident itself. It’s choosing the right next step.

Not every issue deserves the same response. Some require immediate reporting. Others call for escalation. Some simply need to be contained and learned from. The skill lies in recognising which is which — and acting with clarity rather than hesitation.

Below is a practical decision logic to help you navigate those moments, along with the type of professional you would typically involve at each stage.

Facing Incidents With Clarity, Not Fear

Incidents don’t just test your processes — they test you. They trigger doubt, frustration, embarrassment, even the quiet fear that you “should have caught it.” That emotional weight is real, and pretending otherwise only makes it heavier. The truth is that every compliance professional, no matter how experienced, will face moments where something slips, something breaks, or something simply doesn’t go to plan.

What matters is how you respond.

The goal isn’t perfection. It’s honesty, clarity, and the willingness to act. When you approach incidents with a calm, structured mindset, you take the emotion out of the driver’s seat and put good judgment back in control. And when you treat mistakes as information — not personal failures — you create the conditions for real improvement.

Every incident carries a lesson: a weak control, a blind spot, a pattern you hadn’t noticed, a process that needs tightening. Learning from those moments is what turns a compliance programme from something that exists on paper into something that actually protects the organisation.

Incidents in export control rarely arrive with fanfare. They tend to surface quietly — a detail that doesn’t look right, a shipment that raises a question, a moment where something feels off. And in those situations, the real challenge isn’t the incident itself. It’s choosing the right next step.

Not every issue deserves the same response. Some require immediate reporting. Others call for escalation. Some simply need to be contained and learned from. The skill lies in recognising which is which — and acting with clarity rather than hesitation.

Below is a practical decision logic to help you navigate those moments, along with the type of professional you would typically involve at each stage.

1. A controlled item was exported without a licence → REPORT

If a controlled item has left the organisation without the required licence, the incident must be reported. Regulators value early, honest disclosure—it signals transparency and a genuine commitment to compliance.

Whom to contact:

• Export Control Officer – to assess the breach and prepare the disclosure.

• Head of Compliance – to approve the reporting strategy.

• Legal Counsel (Trade/Regulatory) – to ensure the wording meets regulatory expectations.

2. You suspect diversion → REPORT immediately

Any suspicion of diversion requires urgent reporting. Diversion—where goods are redirected to unauthorised users or destinations—poses serious risks. Early warnings help regulators act quickly and effectively.

Whom to contact:

• Senior Trade Compliance Lead – to validate the suspicion and initiate reporting.

• Security or Intelligence/Risk Team – to investigate red flags or unusual behaviour.

• Legal Counsel (Sanctions/Export Controls) – to guide the escalation and protect the organisation.

3. The mistake is internal and contained → Document & IMPROVE

If the issue occurred internally and was fully contained before any external impact, formal reporting may not be necessary. Instead, document what happened and focus on strengthening processes to prevent it happening again. This maintains accountability without over-escalating.

Whom to contact:

• Team Leader or Process Owner – to confirm the scope and containment.

• Internal Audit or Quality Assurance – to document the incident and verify controls.

• Compliance Analyst – to implement corrective and preventive actions.

4. You’re unsure → ASK for guidance

Uncertainty is a signal in itself. When the right path isn’t clear, seek advice. Asking early prevents missteps and ensures the incident is handled responsibly.

Whom to contact:

• Export Control Officer – your first stop for interpretation and clarity.

• Compliance Manager – to help weigh risk and decide the next step.

• Legal Counsel – if the uncertainty involves regulatory interpretation or potential exposure.

5. The incident involves a sensitive destination → ESCALATE

Issues linked to high‑risk or sensitive destinations require escalation. These locations often carry additional regulatory or geopolitical concerns, so they demand heightened scrutiny.

Whom to contact:

• Senior Compliance Leadership – to assess geopolitical and regulatory risk.

• Sanctions Specialist – to evaluate destination‑specific restrictions.

• Legal Counsel (International Trade) – to guide the escalation and documentation.

6. The incident reveals a systemic weakness → REVIEW the programme

If an incident exposes a broader weakness in your compliance system, it’s time for a programme‑level review. A single error can be a symptom of deeper structural issues, and addressing them strengthens both security and compliance.

Whom to contact:

• Chief Compliance Officer – to sponsor a full programme assessment.

• Internal Audit or Enterprise Risk Management – to map the root causes.

• External Trade Compliance Consultant – to provide an independent, unbiased review.

So when something goes wrong, take a breath. Follow the logic. Ask for help when you need it.

And remember: the strongest compliance cultures aren’t the ones that never make mistakes - they’re the ones that learn from them, openly and consistently.