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Export-control diligence for AI hardware

You are liable for where your GPUs end up.
Prove you checked.

ClearEndUse produces the diligence file that shows you screened your buyer, understood the end use, and confirmed the hardware went where they said it would. Delivered in 48 hours, not two weeks.

Book a 20-minute call Request the sample file
Buyer vetting
48-hour turnaround
Site verification
Independent inspector, under NDA
Methodology
Mirrors published BIS guidance
Buyer vetting file
CEU-2026-0912-0417
Sample
BuyerMeridian Compute Holdings Ltd
ItemsECCN 3A090 · 40 × HGX H100 8-GPU
Reviewed2026-09-12 · 14:07 UTC
Screening
  • Entity List v2026-09-10No match
  • Denied Persons · Unverified · MEUNo match
  • OFAC SDN · ConsolidatedNo match
  • UK · EU · JP listsNo match
Beneficial ownership
Meridian Compute Holdings Ltd
└ 100% Meridian Group BV (NL)
└ 62% · A. Verhoeven · 38% · Ostrava Capital LP
Red flags
  • Facility capacity vs. quantityConsistent
  • Ship-to matches stated siteConsistent
  • Freight forwarder as consigneeResolved · see 4.3
Finding Proceed with conditions
The problem

The rules put the burden on the seller.

Export controls on advanced computing chips do not stop at the OEM. Anyone who sells, resells or brokers restricted GPUs and AI servers is expected to know their customer, screen every party, and have a reasonable basis to believe the stated end use is real.

EXPOSURE

Criminal and civil penalties.

Willful violations of the Export Administration Regulations carry penalties of up to $1 million and 20 years per violation. Civil penalties run to the greater of roughly $374,000 or twice the transaction value, per violation. Debarment follows either.

TODAY

Slow and expensive.

A law-firm review of a single buyer takes one to two weeks and bills by the hour. Deals wait. Some die. A list-screening tool tells you a name is not on a list, and nothing else.

THE GAP

Nobody checks after shipment.

Document review ends at the loading dock. Diversion happens after it. No one currently offers independent confirmation of where the hardware was installed.

Two services

Sold separately or together.

Pre-shipment 48h

Buyer vetting

Your buyer completes a structured questionnaire. We screen every party against restricted-party lists, map beneficial ownership, test the stated end use against published red flags, and return a documented diligence file you can put in front of counsel or a regulator.

  • Restricted-party screening across U.S. and allied lists
  • Beneficial ownership mapped to the natural persons behind the buyer
  • End-use plausibility reviewed against BIS red-flag indicators
  • Findings, evidence and a clear recommendation in one file
How buyer vetting works →
Post-shipment Pilot programme

Installation verification

An independent inspector attends the installation site, confirms the hardware is where the buyer said it would be, records serial numbers, photographs the racks, and documents chain of custody. Delivered under NDA to you and to the site operator.

  • On-site attendance at a named facility on a stated date
  • Serial numbers reconciled against your shipping manifest
  • Timestamped photographic record
  • Scoped so the operator never hands configuration data to a counterparty
How installation verification works →
What you receive

A file that stands up when someone asks.

We do not sell software, and we do not sell reassurance. We sell a compliance file that demonstrates reasonable diligence, structured to match the procedures the regulator has already published.

The file is yours. Keep it for the retention period, hand it to counsel, or produce it if asked.

  1. 01
    Scope statementWhat was checked, on what date, against which sources.
  2. 02
    Screening recordEvery party, every list, every result, with list versions and timestamps.
  3. 03
    Ownership mapWho ultimately controls the buyer, with sources.
  4. 04
    Red-flag reviewEach published indicator, tested and answered.
  5. 05
    Evidence appendixQuestionnaire responses, documents received, photographs where applicable.
  6. 06
    Findings and recommendationProceed, proceed with conditions, or do not proceed. In plain language.
Who this is for

Built for the sellers without a compliance department.

Nvidia, Dell and Supermicro have in-house trade-compliance teams. Their distributors, resellers and the secondary-market brokers moving H100s, H200s and B200s between them carry exactly the same legal duties with none of that infrastructure.

If you are one of them, you are also the channel diversion actually runs through, and the one enforcement looks at first.

  • Distributors and VARswith an AI-infrastructure practice reselling OEM hardware.
  • Secondary-market brokerstrading restricted GPUs and servers, often to first-time counterparties.
  • Freight forwardersand logistics brokers handling controlled hardware.
  • Colocation operatorshosting third-party GPU deployments.
Methodology

Modelled on the regulator's own guidance.

In May 2025, BIS published industry guidance on preventing diversion of advanced computing chips. It describes the red flags to look for, the questions to ask, and the diligence a seller is expected to perform.

We treat that document as the specification. Our questionnaire asks its questions. Our screening covers its lists. Our site protocol mirrors the structure of a published end-use check. When you hand our file to counsel, they will recognise the shape of it.

Read the methodology →
Who stands behind the report
[Founder name]Founder. [One or two sentences on relevant background.]
Pricing

Priced against what you pay lawyers, not against software.

Buyer vetting

Monthly platform fee, volume tiers

You know the cost in advance and the turnaround is fixed. Single-file pricing for a first engagement.

Installation verification

Per inspection, by country and complexity

Not a subscription. Someone has to travel. Pilot inspections at cost plus travel.

Combined

Retainer plus per-inspection

A recurring base for vetting with site visits added as your shipments need them.

We will give you a number on the first call. It will be a fraction of a law-firm review, and it will not slow your deal down.

Twenty minutes to find out whether this fits.

Tell us how you screen buyers today and what a stalled deal costs you. We will show you a sample file and tell you exactly what we would do differently.

Book a call Request the sample file