The architecture pattern
A
Controlled shipment ready for release
Freight forwarder waiting · License active
Gate A
↓
Six conditions evaluated simultaneously
Classification · screening · license · destination · forwarder · routing
Authorization gate
B
Electronic Export Information ready to file with AES
ECCN · License reference · Quantity · Consignee
Gate B
↓
EEI validated against compliance record before submission
Every field checked · Discrepancies returned before filing
AES validation gate
C
Payment instruction initiated for controlled transaction
Beneficiary · Correspondent banks · Payment routing
Gate C
↓
Beneficiary screened · Routing evaluated
All clean before transfer initiates · Block at correspondent bank = too late
Payment gate
D
Controlled shipment delivered — transaction complete
License conditions · Post-shipment reporting obligations
Gate D
↓
Obligations tracked from shipment release
Due dates calculated · Completion documented
Post-shipment gate
✓
Evidence generated — Shipment & Payment Compliance Register
Authorization · AES filing · payment screening · Timestamped
Record
Control DNA — Shipment & Payment fields
| Field | Type | What it governs | Review trigger |
|---|---|---|---|
gate_status |
enum |
Whether the shipment authorization gate has been evaluated and passed. Pass, hold, or blocked. Cannot release until confirmed — not assumed. |
Shipment creation |
license_id |
text |
The specific license or exception authorizing this shipment — the license valid now, with current utilization confirmed against authorized quantity. |
Shipment release |
shipments_used |
integer |
Current utilization count against the license's authorized quantity. Tracked in real time. Prevents shipment 26 releasing when only 25 were authorized. |
Each shipment |
routing_authorization |
bool |
Whether proposed freight routing has been reviewed for sanctioned transshipment points before the release instruction is issued. |
Routing change |
aes_validation_status |
enum |
Whether the EEI filing has been validated against the compliance record before submission. Filing errors are violations independent of authorization. |
Pre-filing |
payment_screening_status |
enum |
Whether beneficiary, routing, and payment fields have been screened for sanctions exposure before transfer. |
Pre-transfer |
post_shipment_obligations |
jsonb |
Tracking record for post-shipment reporting, verification obligations, and OFAC reporting windows. The Hub escalates approaching deadlines. |
Shipment delivery |
Failure modes
License management is a spreadsheet
Utilization updated manually when someone remembers. Logistics has no visibility into license conditions. Shipment 26 releases because nobody updated the spreadsheet after shipment 25. Fix: license utilization in logistics system — real time.
Unauthorized shipment
Freight forwarder is trusted, not governed
Screened at onboarding. Routing decisions never reviewed. Transshipment through sanctioned points invisible. Fix: routing approval required before release instruction issued.
Routing violation
AES filing is logistics team's responsibility
Prepared and submitted without compliance review. Nobody compares to compliance record before submission. Fix: pre-filing validation gate — compliance record vs EEI fields.
176 missing filings precedent
Payment compliance is finance's responsibility
Compliance not in payment workflow. Nobody evaluates correspondent bank sanctions exposure for this specific transaction. Fix: pre-transfer payment screening — before funds move.
OFAC block after transfer
Post-shipment obligations discovered at audit
License required post-shipment report within 30 days. Nobody tracked it after shipment released. Fix: obligations tracked from shipment release — Hub escalates approaching deadlines.
Separate violation category
Intelligence signals
Shipment authorization rate
Controlled shipments released with confirmed authorization · Target 100%
License utilization tracking
Alert at 70% · 85% · 95% utilization · Renewal initiated before exhaustion
AES filing accuracy rate
EEI filings passing pre-submission validation · Target 100%
Payment screening coverage rate
Controlled transaction payments screened before transfer · Target 100%
Post-shipment obligation completion rate
Obligations completed within required timeframe · Target 100%
Implementation
01
Six-condition compliance checklist for controlled shipments. Required before release instruction issued to forwarder. All six confirmed in writing.
Checklist · Compliance team sign-off
02
Pre-filing EEI review step. Compliance team compares draft AES filing to shipment compliance record before submission.
Manual review · Pre-filing step
03
Post-shipment obligation checklist created at shipment release. Tracked weekly. Open checklists generate alert until closed.
Spreadsheet tracker · Weekly review
TMS
Shipment authorization integration. Six conditions evaluated in real time. Release instruction blocked until all pass. License utilization tracked continuously.
SAP GTS · MagicLogix · Amber Road
AES
Automated EEI validation against compliance record before submission. Field-level discrepancy flagged. Corrected filing revalidated.
ACE AES Direct · Descartes · Kewill
Pay
Payment screening integration. Beneficiary and routing screened in real time before transfer initiates. OFAC match holds payment for review.
Accuity · Bottomline · SWIFT Compliance