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Global Trade Compliance in 2026: Why Q1 Matters More Than Any Other Time of Year

The start of the year is usually when global trade gaps show up — old access permissions, outdated classifications, missing documentation. Q1 is the best time to get everything back on solid footing. Below are the four straightforward steps we recommend organizations address early in Q1 that make a meaningful difference in reducing risk for the rest of the year: 

1. Revalidate US Munitions List (USML) and Commerce Control List (CCL) Classifications 

Products evolve, software changes, and engineering teams move quickly. It’s worth taking a deliberate look in Q1 to make sure: 

  • Items are properly classified on the USML/CCL 

  • Technology that was updated or modified is reassessed 

  • Your classification notes are documented and audit‑ready 

Having clean classifications on the front end prevents bigger issues later. 

2. Refresh Access Controls 

With staff turnover throughout the year, contractors rolling off, and new hires coming on after the holidays, access lists almost always need attention. Early in the year, confirm: 

  • Ensure access to export‑controlled information is properly controlled 

  • Review access for outdated permissions 

  • Ensure foreign‑person restrictions are correctly applied 

These checks are simple but critical. 

3. Conduct Annual Global Trade Compliance Training 

Training is a compliance requirement and often the only thing preventing accidental exports. Q1 is a good time to:

  • Deliver updated training to employees who come into contact with export‑controlled material 

  • Reinforce rules around email, cloud storage, and day‑to‑day communication 

  • Document completions for your records 

It sets a consistent baseline for the rest of the year. 

4. Review Technology and Data‑Handling Workflows 

Most unintentional violations come from digital workflows. Early in the year, we recommend confirming: 

  • Cloud platforms are configured for ITAR requirements 

  • Encryption tools are working as intended 

  • Vendors and subcontractors remain compliant 

A quick review here goes a long way. 

Why This Matters 

Solid global trade controls reflect professional discipline, protect national security interests, and give partners confidence in your operations. If your organization handles cutting edge products, technical data, or defense services, the first quarter is the right time to get ahead of issues and build a stronger compliance posture for the year. 

Saul Newsome