Chris Chew Export Control Organisation UK Export Control Chris Chew Export Control Organisation

Who are we? The Export Control Organisation (ECO), part of the Department for Business, Innovation & Skills The UK’s single licensing authority for military and dual-use items and for trade sanctions Approx. 80 staff, ~£4m budget Responsible for legal and regulatory framework Outreach and Compliance functions https://www.gov.uk/government/organisations/export-control-organisation

The UK system at a glance Single licensing authority Single IT system – SPIRE – fully end-to-end electronic licensing All applications assessed against Consolidated EU & National Export Licensing Criteria Based on advice from FCO, MOD, DFID, DECC, GCHQ,… Extensive use of “open” (i.e. general and global) licences for “less sensitive” transactions

SPIRE e-licensing system Web-based cross-Government IT system Exporters apply/register for licences online ECO process and circulate applications to advisory departments who review and make recommendations Can send Requests for Further Information (RFI) to applicant Licences issued electronically Licence data sent to customs IT system for Automatic Licence Verification

Consolidated EU and National Arms Export Licensing Criteria UK’s international commitments internal repression internal situation of recipient country regional stability national security of UK and allies behaviour of recipient country diversion economic sustainability

Licence Process 6 6 Applicant Applicant (RFIs) Refusal Meeting LICENCE (application) Applicant (RFIs) Refusal Meeting LICENCE REFUSED Licence Reception Enforcement Unit Technical Assessment Unit Licensing Unit Licence Issued Applicant (Appeal) Advisory Departments H.M.R.C. CHIEF Appeal Rejected DECC CWC NSG DfID CHSD Posts FCO CPD HRDGG IOD Legal Ministers Posts GCHQ CESG MOD EPA DIS DSTL ECP DDefSy Applicant (exports)

Elements of risk assessment…(1) Reviewing an export licence application includes consideration of: The licence application itself Supporting documentation including EUU/EUC Open Source information (but only if reliable!) Diplomatic reporting Classified sources

End-User Undertakings An EUU is required for most individual licence applications (with some important exceptions) Includes: details of end-user / consignee; goods description, quantity & value; statement of intended end-use assurance the goods won’t be used for prohibited end-uses Original, signed & dated; with covering letter

Elements of risk assessment…(2) Who is the intended end-user? the branch or unit, their track-record, organisation structure and links What is the stated end-use? Is it credible? Are quantities/values realistic? What is the nature of the equipment? Can it be used for other purposes, or modified or reverse engineered? Is the level of technology appropriate to the stated end-use? What is risk of mis-use or diversion?

Outcomes 2015 *Some applications refused under more than 1 Criterion Issued 13,653 Revoked 11 Refused 326 NLR 2,087 Withdrawn/Stopped 1,381 Reason for refusal* Number 1 – UK’s international commitments 202 2 – Internal repression 31 3 – Internal situation of recipient country 21 4 – Regional stability 9 5 – National security 43 6 – Behaviour of the buyer country 7 – Diversion 120 8 –economic sustainability *Some applications refused under more than 1 Criterion

Any Questions?