COMPLIANCE
FRAMEWORK
SORC Defence operates in strict accordance with international export control law, defence procurement regulations, and applicable trade compliance frameworks.
All activities conducted by SORC Defence are subject to rigorous legal and regulatory oversight. The firm maintains full compliance with the export control regimes of Canada, the United States, and applicable international frameworks governing the transfer of defence articles, services, and technology.
All brokerage, advisory, and facilitation activities involving US-origin defence articles and services are conducted in full compliance with the International Traffic in Arms Regulations (22 CFR Parts 120–130). The firm ensures appropriate licensing, end-use certification, and retransfer authorisation for all controlled transactions.
Dual-use items and technology subject to the Export Administration Regulations (15 CFR Parts 730–774) are handled with full compliance, including classification, licensing determination, and restricted party screening on all transactions.
As a Canadian-registered firm, SORC operates under the Export and Import Permits Act (EIPA) and the associated Export Control List. All controlled goods and technology exports are subject to Canadian Global Affairs export permit requirements.
Parts sourcing and supply chain activities adhere to NATO codification standards (STANAG 3150 and related agreements), ensuring full NSN traceability, approved supplier qualification, and documentation integrity throughout the supply chain.
The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies governs the transfer of items on the Munitions List and Dual-Use List. SORC applies Wassenaar-aligned controls to all relevant transactions, ensuring participating state obligations are met and that transfers do not contribute to destabilising accumulations.
Where transactions involve UK-origin controlled goods, technology, or software, SORC ensures compliance with the UK Export Control Order 2008 and the Strategic Export Controls licensing regime administered by the Export Control Joint Unit (ECJU). Standard Individual Export Licences (SIEL) and Open General Export Licences (OGEL) are applied as appropriate.
Transactions involving EU-origin dual-use items are subject to EU Regulation 2021/821 (recast Dual-Use Regulation). SORC applies the required licensing determinations, end-use controls, and catch-all provisions for items not listed but potentially contributing to WMD programmes or military end-uses in embargoed destinations.
The Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions. SORC screens all counterparties, beneficial owners, and transaction jurisdictions against OFAC's Specially Designated Nationals (SDN) list and applicable country-based sanctions programmes prior to any engagement.
SORC requires end-use certificates (EUC) and, where applicable, end-user statements (EUS) for all controlled transactions. The firm conducts due diligence on all counterparties and will not facilitate transactions where end-use cannot be verified.
All clients, suppliers, and intermediaries are screened against applicable denied party lists prior to engagement, including: the US Consolidated Screening List (CSL), OFAC SDN and Sectoral Sanctions lists, UN Security Council consolidated sanctions list, EU Consolidated Sanctions List, UK OFSI Financial Sanctions Register, and relevant regional sanctions regimes.
The firm operates under a strict non-disclosure policy. Client identities, requirements, and transaction details are not disclosed to third parties without explicit written consent. All staff and associates are bound by confidentiality obligations.
SORC maintains a zero-tolerance policy on bribery and corruption in all forms. The firm complies with the Canadian Corruption of Foreign Public Officials Act (CFPOA), the US Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act 2010 in all jurisdictions of operation.
In the event of a potential violation of applicable export control or sanctions regulations, SORC maintains a Voluntary Self-Disclosure (VSD) procedure. The firm will promptly assess, document, and where appropriate self-disclose to the relevant authority — including DDTC (ITAR), BIS (EAR), OFAC, or Global Affairs Canada — in accordance with applicable VSD guidelines.
SORC maintains transaction records, export documentation, licences, end-use certificates, and screening records for a minimum of five years from the date of transaction, in compliance with ITAR (22 CFR 122.5), EAR (15 CFR 762), and Canadian EIPA requirements. Records are stored securely and are available for regulatory inspection upon lawful request.
For compliance-related enquiries, licensing questions, or to request a copy of the firm's compliance policy documentation, contact the firm directly.