Established in 2013 by James E. Bartlett III, and Michael E. Farrell, Full Circle Compliance (FCC) is an international trade compliance advisory firm with over 25 years of experience in working with industry, non-profit organizations, and government agencies.  Our senior executives are experts on a wide range of U.S. and European trade laws and regulations, including military and dual-use export controls, sanctions and embargoes, customs, anti-corruption, and anti-bribery.  We assist our clients in identifying and minimizing export risks and streamlining their compliance programs.  

To assist our clients in ensuring compliance and remaining up-to-date with applicable trade laws and regulations, we provide a wide range of compliance services and solutions.  Our core solutions include compliance auditing, risk assessment & risk mitigation, Internal Compliance Program (ICP) development and implementation, classification & licensing services, non-compliance investigations & remediation, trade law annotation, newsletter services, and (web-based) training.

Our practice areas

FCC’s core practice areas can be summarized as follows

Primary U.S. and EU Export Control Laws & Regulations:

  • U.S. International Traffic in Arms Regulations (ITAR)
  • U.S. Export Administration Regulations (EAR)
  • U.S. Foreign Trade Regulations (FTR)
  • EU Dual-Use Export Controls (Council Regulation (EC) No. 2021/821)
  • EU Military Export Controls (Common Position 2008/944/CFSP and the EY Common Military List)
  • Dutch Export Control Laws & Regulations
  • German Export Control Laws & Regulations
  • UK Export Control Laws & Regulations

Subscribe now to our Annotated Regulations to stay up-to-date with the latest ITAR and FTR amendments. 

Primary U.S. and EU Sanctions Regulations:

  • Office of Foreign Assets Control (OFAC) Sanctions Regulations
  • Restrictive Measures of the European Union (EU Sanctions) 
  • U.S. Customs Regulations
  • EU Customs Regulations
  • Design, implementation, and enhancement of Internal Compliance Programs
  • Audits, (risk) assessments, and gap analysis 

Please contact us to find out how we can help you protect your technology and determine automated compliance solutions.

Our Mission

You can be compliant without being ethical, but you cannot be ethical without being compliant.

Our mission is to assist our clients in becoming self-sufficient in international trade compliance. We believe compliance is about more than just meeting regulatory requirements. In today’s globalized and often highly regulated business environment, a robust and effective compliance program is both a quality statement and a license to operate: it creates trust towards business partners and regulating government agencies, enhances confidence among employees, and it keeps your organization in business. Our services and solutions focus on capacity building, enabling our clients to enhance their compliance efforts and utilize compliance as a business enabler, thereby creating a competitive advantage over their (potential) competitors.

Our values

Our core values of Integrity, Quality, and Trust play an integral part in accomplishing our goals and underpinning our reputation.  We uphold our reputation by serving only those clients whom we are competent to serve and who meet appropriate standards of legitimacy and integrity.  We take pride in the fact that our services add value to our clients.  Throughout all our engagements, the following principles are imperative:

  • We lead by example – At all levels acting in a way that exemplifies what we expect of each other.
  • We work together – Bringing out the best in each other and creating strong and successful working relationships.
  • We respect the individual – Respecting people for who they are and for their knowledge and experience as individuals, team members and business partners.
  • We seek the facts and provide insight – Challenging assumptions, pursuing facts, and strengthening our reputation as trusted and objective business advisers.
  • We are open and honest in our communication – Sharing information, insight, and advice frequently and constructively, and managing tough situations with courage and candor.
  • We act with integrity – Constantly striving to uphold the highest professional standards, provide sound advice, rigorously maintain our independence and put our clients’ interests first.


Full Circle Compliance has developed an Internal Compliance Program (ICP) framework that helps you audit, benchmark, and mitigate risks related to your business operations.  We can transform trade compliance issues into a distinct commercial advantage over your competitors.  We train, educate, and support all professionals involved, and help them utilizing compliance as a business enabler, while minimizing the risk of non-compliance situations that could disrupt business operations and limit their access to important technologies and export markets.

 The advantage of the Full Circle Compliance ICP framework is that it incorporates all the essential elements of official guidelines written by primary U.S. and European government agencies and models designed by advisory committees (including COBIT, COSO, Nunn-Wolfowitz).  An ICP is never a one-size-fits solution.  We are pleased to help you tailor it to your needs and ambitions, industry and business operations, in a way that it covers applicable regulatory requirements and mitigates your risks.  Our framework is explained in more detail in our White Paper.

Meet the team


James E. Bartlett III

More about James

Michael E. Farrell

More about Michael

Marco Crombach

More about Marco
Senior Manager

Elina Tsapouri

More about Elina

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