For Chief Compliance Officers (CCOs) in the steel industry, few areas of regulation are more complex—or more risky—than dual-use exports. These are materials and products that have both civilian and military applications. In steel, that includes certain high-strength alloys, corrosion-resistant grades, and specialty coatings. The consequences of getting this wrong can be serious: steep fines, loss of export privileges, or even criminal penalties.

But the regulations aren’t always black and white. Dual-use control regimes are constantly evolving, with shifting thresholds, end-user restrictions, and geopolitical considerations. That means steel CCOs have to be hyper-vigilant—not just once a year, but every single day.

What Exactly Is a Dual-Use Steel Product?

Dual-use items are not weapons, but they can be used to manufacture them—or support military or strategic infrastructure. In the steel sector, some of the most commonly scrutinized products include:

High-tensile strength steel used in aircraft or naval vessels

Corrosion-resistant or heat-treated alloys for nuclear or aerospace use

Structural components for defense-related infrastructure

Depending on the country of origin and the destination, even seemingly standard items could be considered dual-use. That’s where export classification becomes critical.

Understanding the Regulatory Landscape

Globally, the two most significant frameworks that affect steel exports are:

The Wassenaar Arrangement: A multilateral export control regime covering dual-use goods and technologies, including certain categories of steel.

National Export Control Laws: Such as the U.S. Export Administration Regulations (EAR), European Union Dual-Use Regulation, or China’s Export Control Law.

Each of these frameworks can impose licensing requirements, documentation rules, and audit obligations. For example, if you’re exporting from the U.S., even to an allied country, you may still need a license depending on the material, destination, and end user.

Key Risks for Steel Exporters

As a CCO, you’re responsible for identifying and managing risks. When it comes to dual-use regulations, those risks include:

Misclassification: Failing to properly classify a material can result in unlicensed exports.

End-Use Violations: Even if a material is legal to export, its use in military projects or sanctioned industries may be restricted.

Denied Party Transactions: Shipping to a blacklisted company or country, even unintentionally, is a serious offense.

False Documentation: Any inaccuracies in export paperwork—whether deliberate or accidental—can lead to severe penalties.

Daily Responsibilities of the Steel CCO

Navigating these rules isn’t a once-a-quarter compliance task. It’s a daily responsibility. Here’s what the most effective CCOs do to stay compliant:

Monitor Regulatory Changes: Track updates from export control authorities in relevant jurisdictions.

Screen Transactions in Real Time: Use denied party screening tools for every quote, order, and shipment.

Review Export Classifications: Confirm the correct ECCNs (Export Control Classification Numbers) or national equivalents for all materials.

Verify End-Users and End-Use: Ensure that customers are not using materials in restricted applications or forwarding them to embargoed regions.

Train Sales and Shipping Teams: Everyone who touches an international order must understand the basics of dual-use compliance.

Leveraging Technology to Stay Ahead

Compliance technology can significantly reduce the workload—and the risk—associated with dual-use exports. AI-driven platforms can:

Flag high-risk materials based on specs and customer profile

Screen against real-time sanction and embargo lists

Store and audit export documentation automatically

Track license usage and expiration

These tools don’t replace the CCO—but they empower the team to act with speed and confidence.

Licensing Isn’t Always a Dealbreaker

One of the most common misconceptions is that a dual-use classification ends the business opportunity. That’s not always true.

Many jurisdictions allow export of dual-use steel materials under license. The key is knowing when a license is required, how to apply, and how long the process will take.

CCOs who work closely with legal and logistics teams can often structure deals to stay compliant and still serve international markets. It’s not about saying “no”—it’s about saying “yes, if we follow these steps.”

Penalties Are Real, and Reputational Risk Is Even Greater

Failure to comply with dual-use export regulations can trigger massive fines—often in the millions of dollars. But the reputational risk can be even more damaging. A single headline tying your company to an unauthorized export can lead to lost customers, stricter scrutiny, and investor concern.

Being known as a company that takes compliance seriously can actually be a competitive advantage. Customers—especially those in infrastructure, defense, or energy—want to work with suppliers who understand and manage export risks.

Final Thought: Compliance Is a Strategic Role

In the steel industry, compliance isn’t about checking boxes. It’s about enabling responsible, sustainable growth. For CCOs, dual-use export control is where legal expertise meets operational insight.

Get it right, and your company can expand globally with confidence. Get it wrong, and the consequences could stall your business for years.

Stay current. Stay diligent. And always assume that what looks like ordinary steel might have extraordinary consequences if misclassified.

Your diligence today protects your company tomorrow.