1. Chris Chew Export Control Organisation
UK Export Control
Chris Chew
Export Control Organisation

2. 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

3. 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

4. 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

5. 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

6. 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)

7. 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

8. 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

9. 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?

10. 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

11. Any Questions?