The ECO reports directly to the Head of Engineering, whose primary focus is project delivery deadlines. This reporting structure creates a potential conflict of interest and limits the ECO’s ability to act independently. They also lack a dedicated budget for essential compliance tools, training, and external legal advice, hindering the development of a robust program.

GlobalTech's engineers routinely share technical data, including DSGL and ITAR-controlled information, via unsecure email and cloud platforms. There's no formal process for screening recipients or documenting these exchanges. This "intangible supply" to foreign persons is a major exposure point, particularly under the new Australian Defence Trade Controls Act (DTCA) and US "deemed export" rules.

The company relies on its engineers to self-classify components, often without formal training or a consistent process. There is no centralised register to track item classifications (DSGL, USML, ECCN) or to monitor the status and expiration dates of licenses and permits. This ad-hoc approach increases the risk of misclassification and non-compliance with license conditions.

GlobalTech's ECCP has not been updated to address the requirements of the SAMS Act or the AUKUS LFE. The company has no internal policy or training on protecting Sensitive Military Information as required by the SAMS Act. Furthermore, while they hope to leverage the AUKUS LFE for the new contract, they lack the necessary procedures for stringent eligibility screening and ongoing compliance management.