Operate and maintain Isembard's export-control programme across goods, software and technical data, with hands-on UK, EU and US experience.
Role overview
- Reporting to: Legal.
- Location: UK (with travel to Company and customer sites as required).
- Business unit: Compliance & Legal.
- Employment type: Full-time.
Purpose of the role
The Export Control Officer is responsible for operating and maintaining the Company's export-control programme across its distributed manufacturing operations, ensuring that the transfer of goods, software and technical data complies with applicable U.S., UK, EU and other export-control and sanctions regimes. The role carries primary day-to-day responsibility for export control compliance, including classification, licensing, technology-control planning and the control of access to controlled technical data by employees, contractors and foreign persons. The role operates in a defence and aerospace manufacturing environment handling controlled hardware, software, source code and technical data, and requires close working with engineering, IT security, operations, procurement, legal and senior management.
Key responsibilities
Export-control programme
- maintain, implement and continuously improve the Company's export-control compliance programme, policies and procedures;
- act as a principal point of contact for export-control matters internally and with regulators and customers; and
- maintain the Company's registrations, records and filings, including ITAR registration.
Classification
- classify goods, software and technical data under the applicable UK, EU or US dual-use and military control lists or jurisdictional equivalent; and
- maintain classification records and rulings and manage commodity-jurisdiction and classification requests.
Licensing and authorisations
- prepare, submit and manage export licences, agreements and authorisations;
- manage licence conditions, provisos, reporting and record-keeping obligations; and
- determine licensing routes for exports to permitted destinations and identify and manage diversion risk, including sanctions-driven risks.
Technical data and access controls
- operate technology control plans (TCPs) governing access to controlled technical data by employees, contractors and foreign persons;
- assess and manage deemed-export and deemed-reexport risks, including employee access, restricted zones and remote or cloud access to controlled technical data; and
- advise on the conditions for storing and transmitting controlled technical data, including cloud infrastructure and applicable end-to-end encryption carve-outs.
Sanctions and counterparty diligence
- conduct restricted-party, sanctions and end-user screening of customers, suppliers and other counterparties; and
- assess and document sanctions exposure under UK, EU and US regimes.
Training, audit and reporting
- deliver export-control training and awareness across the business;
- conduct internal audits, assessments and corrective actions, and maintain audit trails;
- identify, investigate and remediate potential violations and manage voluntary disclosures where required; and
- report on export-control performance, risks and incidents to senior management.
Essential knowledge, skills and experience
- Demonstrable hands-on knowledge of UK export licensing (SPIRE / LITE), EU dual-use controls, and U.S. ITAR, including classification, licensing and technology-control planning across regimes.
- Working knowledge of the U.S. EAR, including CCL classification and EAR99 determinations.
- Working knowledge of UK, EU and U.S. sanctions regimes and restricted-party screening.
- Experience operating an export-control compliance programme in a defence, aerospace or advanced-manufacturing environment handling controlled hardware, software and technical data.
- Understanding of deemed-export and deemed-reexport principles and access controls for foreign persons.
- Familiarity with CUI/CDI concepts and DFARS safeguarding requirements.
- Strong analytical skills, accuracy and attention to detail in classification and record-keeping.
- Ability to communicate complex regulatory requirements clearly to technical and non-technical stakeholders.
Desirable knowledge, skills and experience
- Professional export-control certification.
- Experience managing TAAs and MLAs through their lifecycle.
- Experience of cloud and remote-access environments for controlled technical data.
- Relevant degree or professional qualification in law, international trade, engineering or a related discipline.
Eligibility and clearance
The role may require eligibility to access controlled technical data, which may be subject to nationality, residency, security-clearance or licensing conditions. The successful candidate must satisfy applicable pre-employment screening and any export-control or security-clearance requirements.
Key relationships
- Internal: engineering, IT security, operations, procurement, legal, and senior management.
- External: regulators, customers, suppliers, external counsel and screening providers.
Performance measures
- Accuracy and timeliness of classifications, licence applications and screening.
- Maintenance of a current, auditable export-control compliance programme.
- Effectiveness of training and awareness across the business.
- Timely identification, escalation and remediation of compliance risks and incidents.