Distributors are widely used by manufacturers to reach markets that they would not otherwise be able to penetrate. Russia’s and China’s need to acquire a wide range of controlled and noncontrolled technology for their strategic programs highlights the particular risk that distributors could be used by those countries as routes through which to acquire western technology that would not be sold if the approach was made directly to the manufacturer. In this document, repeated use is made of the term ‘trusted distributor’, implying that distributors should not be used unless trusted. Trusted in this context is an imperfect term but is meant to convey that the manufacture has confidence that the distributor will conduct an equivalent level of due diligence as the manufacturer would and would reach a comparable decision on whether or not to undertake a transaction. In practice, companies must be wary of the use of distributors. For many controlled goods, there is an expressed expectation that the goods not be sold through distributors. Even when use of distributors is permitted, there are documented cases in which distributors have been complicit in shipping goods to prohibited end uses for additional profit. 
Particularly in relation to Russia, companies should exercise caution in relation to distributors that are Russian owned or controlled – regardless of where in the world they are – and where a distributor is located in Russia’s near abroad and specializes in selling into the CIS market. In both cases, there are recent examples of distributors shipping western-origin goods to Russia’s strategic programs without the knowledge of the manufacturer.
Good practices for use of distributors including some level of transparency around to whom the distributor is shipping (recognizing that the distributor may wish to keep this confidential so as to ensure the manufacturer cannot bypass them in selling to clients), some level of training and audit on the export compliance by the distributor, and a formalized commitment from the distributor about the sanctions and export control approach they are to take.
 See for example, “Chinese Citizen’s Involvement in the Supply of MKS Pressure Transducers to Iran: Preventing a Reoccurrence”, Available online at: https://isis-online.org/uploads/isis-reports/documents/MKS_China_30Apr2014-final.pdf (Accessed 1 August 2022)