1. Purpose
This Export Compliance Policy outlines the commitment of WarMind Labs, S.L. ("WarMind Labs") to comply with all applicable export control, trade sanctions, and anti-proliferation laws and regulations. Given the nature of our work in cognitive artificial intelligence applied to warfare, defense, and security (WDS), strict export compliance is a fundamental requirement of our operations.
2. Scope
This policy applies to:
- All employees, contractors, consultants, and agents acting on behalf of WarMind Labs
- All products, technologies, software, technical data, and services developed, provided, or transferred by WarMind Labs
- All business relationships, including those with partners, clients, subcontractors, and end-users
3. Regulatory Framework
WarMind Labs operates under the following export control regimes:
3.1 European Union
- EU Dual-Use Regulation (Regulation (EU) 2021/821)
- EU Common Position on Arms Exports (Council Common Position 2008/944/CFSP)
- EU sanctions and restrictive measures
3.2 Spain
- Spanish Law on Foreign Trade in Defense and Dual-Use Material (Ley 53/2007)
- Regulations administered by the JIMDDU (Junta Interministerial Reguladora del Comercio Exterior de Material de Defensa y de Doble Uso)
3.3 International
- Wassenaar Arrangement
- Missile Technology Control Regime (MTCR)
- United Nations Security Council Resolutions (UNSCRs)
- Where applicable: U.S. International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR)
4. Key Commitments
- Classification: All products, technologies, and services are reviewed and classified under applicable export control lists (EU Dual-Use list, Spanish military list, and where relevant, U.S. USML/CCL).
- Screening: All parties involved in transactions (end-users, intermediaries, consignees) are screened against relevant denied-party, sanctions, and embargo lists, including EU, UN, OFAC, and BIS lists.
- Licensing: Where required, WarMind Labs obtains appropriate export licenses or authorizations before transferring controlled items, technology, or technical data.
- End-Use/End-User Controls: We assess the stated end-use and end-user of all transactions involving controlled items to prevent diversion to unauthorized parties or prohibited uses.
- Record-Keeping: We maintain complete records of all export-related transactions, classifications, and compliance activities as required by law.
5. Technology Transfer and Deemed Exports
WarMind Labs recognizes that the transfer of controlled technical data or technology to foreign nationals, even within Spain or the EU, may constitute a "deemed export" under certain regulations. We apply appropriate controls to:
- Restrict access to controlled technical data based on nationality and authorization
- Apply Technology Control Plans (TCPs) where required
- Ensure that foreign national employees or contractors are properly vetted and authorized
6. Responsibilities
6.1 Management
Senior leadership is responsible for establishing an export compliance culture and ensuring adequate resources are allocated.
6.2 Export Compliance Officer (ECO)
A designated Export Compliance Officer oversees the implementation and enforcement of this policy, conducts training, manages licensing, and serves as the primary point of contact for compliance matters.
6.3 All Personnel
Every employee and contractor is responsible for understanding and following export compliance requirements relevant to their role.
7. Training
WarMind Labs provides export compliance training to all relevant personnel upon onboarding and on a periodic basis. Training covers:
- Overview of applicable export control laws
- Classification procedures
- Red flags and due diligence
- Reporting obligations
8. Violations and Reporting
Violations of export control laws can result in severe civil and criminal penalties, including fines, debarment, and imprisonment. Any employee or contractor who becomes aware of a potential violation must report it immediately to the Export Compliance Officer. WarMind Labs has a zero-tolerance policy for knowing or willful violations.
9. Audits and Reviews
Internal compliance audits are conducted periodically to assess the effectiveness of this policy and identify areas for improvement. Findings are reported to management and addressed promptly.
10. Policy Review
This policy is reviewed at least annually and updated as necessary to reflect changes in applicable laws, business activities, or organizational structure.
11. Contact
For export compliance inquiries, contact:
WarMind Labs, S.L. - Torre Juana, Alicante, Spain - Email: info@warmindlabs.com