The architecture pattern
A
New engineering object created
PLM · CAD · Code repository
Gate A
↓
ECCN / USML assigned at creation
Required field · Cannot advance without it
Creation gate
B
Engineering change order filed
Hardware · Software · BOM substitution
Gate B
↓
Classification impact assessed
Auto-triggered · Compliance sign-off before ECO closes
Change gate
C
Controlled repository access requested
Foreign national · Contractor · New project
Gate C
↓
TCP validated · Identity confirmed
IAM enforced · Access logged with timestamp
Access gate
D
Technical data transfer initiated
Email · Cloud sync · Contractor share
Gate D
↓
DLP intercepts · Authorization confirmed
Transfer logged · Unauthorized transfers blocked
Transfer gate
✓
Evidence generated automatically
Controlled Technology Register · Timestamped
Record
Control DNA — R&D fields
| Field | Type | What it governs | Review trigger |
|---|---|---|---|
eccn |
text |
Export Control Classification Number. Assigned at object creation. Must live in the PLM — not a spreadsheet. |
ECO filed |
jurisdiction |
enum |
EAR or ITAR. Determines which regulatory framework governs every downstream decision. |
Creation |
reason_for_control |
text[] |
AT, NS, RS, MT, etc. Required for license determination at export. Created in R&D. Used at shipment. |
Classification |
partner_eccn |
text |
Classification of incorporated partner technology. If unknown — product classification is unknown. |
BOM add |
fdpr_applicable |
bool |
Foreign Direct Product Rule. US-origin technology embedded in a product carries EAR obligations regardless of manufacture location. |
Partner tech |
tcp_reference |
text |
Technology Control Plan governing foreign national access. Must be enforced by IAM — not just documented. |
Access req. |
classification_date |
timestamp |
When classification was last confirmed. Staleness is a signal — the Intelligence Hub watches the gap. |
Any change |
bom_impact_reviewed |
bool |
Has every BOM component been reviewed for classification impact? False = exposure forming silently. |
BOM change |
Failure modes
Classification lives in a spreadsheet
Engineering operates in regulatory blindness. Every downstream system inherits the blindness. Fix: required ECCN field in PLM.
Enforcement risk: high
Partner classifications assumed
Agreement doesn't require disclosure. Team assumes EAR99. Module is 3A001. Product ships against wrong classification. Fix: mandatory classification field in partnership agreement template.
$17M+ precedent
ECO process has no compliance step
Changes close without classification impact review. Gap widens with every change. Fix: one required sign-off field in ECO workflow.
Cumulative drift
TCP is a document, not a control
Policy exists. Access control system has never been configured to enforce it. Fix: IAM integration — access granted only when TCP is current.
Deemed export risk
Contractor access is perpetual
Project ends. Access doesn't. Fix: access expiry tied to contract end date, enforced automatically by IAM.
Ongoing exposure
Intelligence signals
Classification coverage rate
Below 95% = gap · Below 80% = crisis
Change review rate
ECOs with documented impact assessment · Target 95%+
Partner classification coverage
Target 100% · Any gap = unknown product identity
Access integrity rate
Foreign nationals with current TCP · Target 100%
External transfer volume
Authorized transfers logged · Anomalies flagged
BOM classification drift
Components without documented classification · Target 0
Implementation
01
Add required ECCN field to PLM item creation. Item cannot be released without it.
PLM custom field · No budget required
02
Add classification impact question to ECO process. Route to compliance if yes.
Workflow modification · SharePoint / Jira
03
Audit controlled repository access. Suspend every foreign national without a current TCP immediately.
Manual audit · This week
PLM
Classification in SAP PLM, Windchill, or Teamcenter. Required field + change gate automation. Propagates to ERP.
SAP GTS · OCR ECM · Vatix
IAM
TCP enforcement at access request. Foreign national status verified. Access logged automatically.
Okta · Entra ID · Pathlock
DLP
Controlled data classified at creation. Outbound transfers monitored. Unauthorized transfers blocked.
Microsoft Purview · Forcepoint