Export Controls and Sanctions Survey Report | 2021

Balancing business priorities and risk realities

Steven Brotherton

Steven Brotherton

U.S. & Global Export Controls & Sanctions Leader, KPMG US

+1 415-963-7861

Elizabeth Shingler

Elizabeth Shingler

Senior Manager, Tax, Trade & Customs Services , KPMG US

+1 267 256 2691

In February 2021, KPMG engaged export and sanctions professionals at multinational firms to gather their input on a variety of business-critical issues. 

Spanning a broad range of companies in terms of size and industry, the survey focused on understanding how export controls and sanctions programs are organized, the most relevant global regulations with which they must comply, the regions/countries they export from and to, and their primary exports, among other items.

The objective of this survey is to provide insight into the export controls and sanctions landscape and an analysis of the state of compliance programs across industries, from regulations and audit to training and technology. 

Through these results we hope to help companies maximize the effectiveness of existing export controls and sanctions compliance programs by getting a better handle on their current and future risks, identifying program gaps, setting a benchmark against their peers, and charting a path forward.

Are companies prepared for a complex future?

What did we learn about our respondents?

Transactions in North America, the EU and Asia Pacific are driving export activity. This means that compliance professionals are managing multiple export regimes—and we anticipate that regulations in these jurisdictions will be tightening. 




Almost 90% of respondents say there is a person or team at their organization specifically dedicated to managing export controls and sanctions compliance.



About 40% say they don’t perform regular audits of their export controls and sanctions program, or don’t know, if they do.



25% don’t have, or don’t know if they have, a documented export controls or sanction program with formal policies, processes and procedures.



Almost 80% use an automated solution to conduct restricted party screening.

Training is key

While 99 percent of survey respondents said their export compliance program is impacted by U.S. laws and regulations—far outpacing all other regions and countries—95 percent of the world’s consumer base is located outside the United States1, demonstrating the importance of ensuring personnel remain educated through comprehensive ongoing training.

Does your company provide ECS compliance training?


Yes 82% 
No 17%
Unknown 1%

Is an adequate understanding of export compliance within your company?


Yes 46% 
No 44%
Unknown 10%


Source:  (1)   Export-Import Bank of the United States.

Risk assessments and key controls

Often companies focus on conducting audits—but audits will not be effective unless the company understands what’s driving their risks. Regular, robust risk assessments coupled with key control identification and management can help compliance professionals establish meaningful audit plans. Key controls are the glue for the entire compliance program. Every export compliance program has core controls from which other compliance determinations are made. 

When did your company last conduct an export controls and sanctions risk assessment?


Less than 1 year ago 45% 
1-2 years 27%
More than 2 years ago 14%
Never 5%
Unknown 10%

Does your company have a matrix for monitoring key controls within ECS processes?


Yes 45% 
No 45%
Unknown 11%


Risks evolve in response to business decisions or regulatory changes. But they can’t be prioritized if they are not fully understood—risk assessments provide the transparency needed to develop a compliance plan that will enable compliant transactions. Key controls are the guardrails in an effective program, so actively monitoring and validating them will help ensure risks are appropriately managed.

Read the survey report

Export Controls & Sanctions Survey Report - Spring 2021
In February 2021, KPMG engaged export controls and sanctions professionals at more than 100 multinational firms to gather their input to better understand how export controls and sanctions programs are organized, the most relevant global regulations with which they must comply, the regions/countries they export from and to, and their primary exports, among other items.

How KPMG can help

The KPMG Global Export Controls and Sanctions practice provides support on a wide range of global regulations, including those administered by the U.S. Department of Commerce, Bureau of Industry and Security, U.S. Department of State, Directorate of Defense Trade Controls, U.S. Department of Treasury, Office of Foreign Assets Control, and other government agencies. 

Our services are tailored around your unique business needs, helping you comply with export controls and sanctions regulations while facilitating business. We evaluate business activities and internal controls to identify and mitigate risks related to global trade. When potential violations occur, we assist investigations through our advanced forensic technology solutions and global reach to help identify issues that may otherwise go undiscovered, especially as it relates to complex global trade and financial networks.