About Us

We are proven and trusted

We will enable you to create a competitive edge while other organizations struggle to comply with international trade laws. We support you first by bringing clarity to issues related to global export control, then by guiding you through all the relevant laws and regulations. We know the most affected industries from the inside, and have experience in dealing with governments, NGOs, corporations, and public-private partnerships.

We have over 25 years of hands-on experience in international trade compliance, and have developed an export control framework to structure all activities related to trade compliance. This allows us to categorize, benchmark, prioritize, and manage risks, and help you to avoid trade compliance violations.

The same experience enables us to integrate trade compliance with existing systems and methodologies. As with most integrity-related issues, the best guarantee for a truly compliant organization is when everyone involved is fully aware of the importance of compliance, and knows what is expected of all employees. In addition, the successful implementation of trade compliance in an organization includes cost effectiveness and minimal disruption to employees. But above all, our services will assist you to learn how to educate your employees to be self-compliant, and not have to rely on repeated help from external consultants.

Who is FCC

Meet the team


Ghislaine-GillessenGhislaine C.Y. Gillessen, Partner and Managing Director. Ghislaine Gillessen has a Master’s degree in Economics and Business Administration, and is a member of the Netherlands Institute of Chartered Accountants. She was the first independent auditor to be contracted by the Dutch government to perform a trade compliance audit of the Dutch Ministry of Defense, and to advise the Dutch government on several bilateral and multilateral trade treaties. She advises multinational corporations on framework integration of complex legislation. Ghislaine is also the driving force behind, and Honorary Lecturer in, the Executive Master’s in International Trade Compliance (EMITC) program, which Full Circle Compliance has set up in cooperation with the University of Liverpool in London. Before joining FCC, Ghislaine set up the trade compliance audits and risk assessment specialty practice at PwC.



james_bartlettJames E. Bartlett III, Partner and Director. Jim Bartlett is an attorney, author, and frequent lecturer in international trade (including Honorary Lecturer at the EMITC program), with a specialty in arms and defense technology trade compliance. He is the author of several books on international trade controls, including Bartlett’s Annotated ITAR (“BITAR”; the International Traffic in Arms Regulations), Bartlett’s Annotated FTR (“BAFTR”; the Foreign Trade Regulations), and co-author of U.S. Export Controls, 7th Edition (2015). Jim is also the editor and publisher of The Export/Import Daily Update (“The Daily Bugle”) a newsletter with more than 7,500 world-wide subscribers at over 500 companies and government agencies. He has J.D. and LL.M. law degrees, and is a licensed U.S. Customs broker. Before joining FCC, Jim was Senior Counsel, Export/Import Law, for Northrop Grumman Corporation, and Assistant General Counsel for the U.S. Defense Intelligence Agency.



Mike-FarrellMichael E. Farrell, Partner and Director. Michael Farrell has advised major companies in several sectors (energy, defense, and electronics) on export compliance, and was a representative to the Aerospace and Defense Industry Association in Brussels. Mike has dealt with the setting up, remediating and mitigation of various International Trade Compliance programs. He has developed a trade compliance management system, including audit methodology, that became a widely accepted industry standard. Mike has proven experience in working with large multinationals as well as small and medium-sized enterprises, in the Oil & Gas, Aerospace & Defense, Manufacturing, Logistical, and financial sector, and with a Ministry of Defense, including their associated programs and (sub)contractors (JSF, F-16, Apache, Chinook).  He spreads his knowledge and experience across industries and as Honorary Lecturer within the EMITC program. Before joining FCC, Mike was a partner at PwC, specializing in consulting and lecturing on global export compliance, risk mitigation, and secure collaboration to universities, companies, and governments in the EU and U.S.



Alexander P. Bosch, Senior Associate. Alexander Bosch has, due to his multidisciplinary academic background, a good overview of how the world of trade compliance is constructed. He is responsible for the drafting of engagement proposals, writing policies and procedures and designing an Internal Compliance Program, performing compliance assessments, audits, investigations related to (potential) export control violations, and is assistant editor of FCC’s daily newsletter, The Export/Import Daily Update (“The Daily Bugle”). In addition, Alexander plays a key role in the development and teaching of FCC’s training programs, and the Executive Masters in International Trade Compliance (EMITC) program, which FCC has set up in cooperation with the University of Liverpool London Campus. Alexander previously was responsible for a project for the Dutch government in which he assessed the effects of the U.S. Export Control Reform (ECR) upon the Dutch government and industry. He has earned his Master’s degree in International Relations from the University of Groningen and has written his master-thesis on the subject of European defense cooperation.



Marco F.N. Crombach, Senior Manager. Marco Crombach has worked for 14 years for Koch Industries Inc., where he led a Customs and International Trade Compliance department for 5 years. By challenging the International Trade Compliance concept, he brought the International Trade Compliance organization to a world-class level. Marco is a Conceptual & Analytical thinker who can lay the foundation for tailor-made applications, for collecting, processing and presenting data to various levels of an organization. Marco is writer of Global International Trade Compliance Policies & Procedures, International Trade Compliance Metric & KPI Dashboards, and Global Customs & International Trade Compliance Manuals. Also, he is a key-player in the implementation of SAP Global Trade System (GTS) module (Blue Print, Design, GAP analysis, Configuration & Training Staff), and he is responsible for the Architecture & Design of Microsoft® SharePoint.®



Vincent J.A. Goossen, Program Manager. Vincent Goossen joined FCC in late 2015. During recent engagements, Vincent was involved in drafting engagement proposals, performing compliance audits/assessments, writing policies and procedures, and designing an Internal Compliance Program, investigating potential non-compliance issues, and handling voluntary disclosures. Since September 2016, he is also assistant editor of FCC’s daily newsletter, The Export/Import Daily Update (“The Daily Bugle”). Vincent previously was responsible for a research project for the Dutch Ministry of Foreign Affairs in which he assessed the background, content and impact of the U.S. strategic “pivot” towards Asia upon the the Netherlands and NATO-partners. He has earned his Master’s degree in History of International Relations from the University of Amsterdam.



Alexander Witt, Associate. Alex Witt is the newest member of FCC. Alexander holds a Bachelor’s degree in International Relations & International Organizations (IRIO) from the University of Groningen and a Master’s degree in International Relations (IR) from the Leiden University. During his studies he gained a lot of valuable experience through multiple internships, including the Stockholm International Peace Research Institute (SIPRI), the Centre for Humanitarian Dialogue (HD) in Geneva, and the Dutch-German Chamber of Commerce (DNHK) in The Hague. Alex conducted extensive research on international sanctions, and developed a sanctions database, bringing together all UN, US and EU sanctions into one database. At FCC, his main responsibilities include drafting engagement proposals, providing support during audits and assessments, drafting policies & procedures for an Internal Compliance Program, and developing social media content and strategies.


Bob is our office mascot, and together we will assist you in making your organization self-sufficient in becoming and remaining trade compliant.  Whether you need “teckle” advice, training, risk-assessment, gap analysis, compliance assessment, audit or investigation together we have the knowledge, experience, and enthusiasm to make your organization shine even more.


Our Network

To succeed in an international business environment, your company must be well connected to a professional network that provides you with reliable information, and allows you to be heard and well regarded. Based on the long professional careers in this vital specialty of the compliance world, the partners of Full Circle Compliance have created a rich web of valuable connections available to benefit your company.


  • Department secretaries
  • Ambassadors
  • Military officers
  • Export compliance officers
  • Government officials
  • Members of parliament 


Authorities in the Netherlands:

  • Ministry of Economic Affairs
  • Ministry of Finance
  • Ministry of Defense


Authorities in other EU members:

  • Germany: BAFA
  • UK: Ministry of Foreign Affairs, various embassies and the Bureau of Innovation & Skills
  • Belgium: Flemish Department of Economic Affairs


Significant senior contacts at US government:

  • Department of Commerce (Bureau of Industry and Security)
  • Department of State (Directorate of Defense Trade Controls)
  • Department of Treasury (Office of Foreign Assets Control)
  • Department of Defense (Acquisition Technology & Logistics, Joint Program Office)
  • Department of Homeland Security (Immigration and Customs Enforcement)

Middle East:


  • Saudi Arabia
  • United Arab Emirates