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UK Export Control Consultants

UK Export Consultants

Institute of Export and International Trade

Established in 1935, the Institute of Export & International Trade is the professional membership body representing and supporting the interests of everyone involved in importing, exporting and international trade.

Offering a unique range of individual and business membership benefits and a world renowned suite of qualifications and training, the Institute is the leading authority in best practice and competence for businesses trading globally.

Export Support Service (ESS)

What is ESS?

The Export Support Service is a new helpline and online service where all UK businesses can get answers to practical questions about exporting to Europe. The service is a ‘one-stop shop’ and brings together UK government information, making it easier for exporters to access advice and support.

Timing:

The helpline and digital enquiry service launched on 1 October.

  • The Export Support Service is a new government helpline and online service where all UK businesses can get answers to practical questions about exporting to Europe
  • It gives access to cross government information and support all in one place
  • If you are a UK business you can use this free service, no matter the size of your business or which part of the UK you are based
  • DIT will continue to work with businesses and business representative groups from all sectors, in all parts of the UK, to help make the service as useful as possible for businesses
  • You can access the Export Support Service at UK/ask-export-support-team or by calling 0300 303 8955 where you will be put in touch with a member of our dedicated export support team

United Kingdom strategic export controls annual report

Annual overview of the UK’s strategic export controls policy and licensing regime.

From: Export Control Joint Unit, Department for International Trade, Ministry of Defence, and Foreign, Commonwealth & Development Office
Published: 26 July 2021

Annual reports include information on:

  • export licensing processes, procedures and responsible departments
  • export licensing data and performance statistics
  • policy developments
  • outreach activity
  • UK support to allies and partners
  • international policy and regimes
  • compliance and enforcement
Documents
UK strategic export controls annual report 2020 – 27 July 2021- Corporate report

British Export Control [BEC] is a cadre of ex UK Govt. and EU export control experts, now supporting Governments and businesses throughout the world.

​We provide a range of bespoke training , support and guidance to all levels of business from one man concerns, large scale manufacturers, Financial institutions and Governments .

BEC evolved from its training wing, Arms Trade Training [ATT] which has been providing, primarily via EU and UN funding training, outreach and support to Governments throughout the world seeking to implement both the UN arms trade treaty and the Dual use [WMD] requirements of UNSCR 1540. Feedback from UK entities indicated that whilst the Department of International Trade provides export control seminars, they are intermittent and of course cover a wide spectrum, if you are a company exporting night vison equipment, a day spent on WMD materials and chemicals may not be the optimum use of your time and budgetary resources, so ATT can provide a similar course to DIT or one tailor made for your company. Our staff have trained UK Customs, HMRC investigators, Border Force, UK intelligence agencies amongst others, in export control and lectured internationally. For those in Academia, Media and literary works, we have also operated at the highest levels of international counter proliferation.

​In addition to routine UK export controls, BEC specializes in those companies involved in moving Military goods from third country to third country, referred to in UK legislation [Export control order 2008] as the Trade controls or more euphemistically as Brokering. The brokering laws can cover any UK person, anywhere in the world that may be involved in a transaction arranging the international transfer of military or paramilitary goods. This can include Banks, insurers, shippers, Military training providers, airlines. In addition of course, there are the range of Trade/Financial sanctions and the Bribery Act (which it seems is being rigorously enforced now)

At BEC, we concentrate on UK based companies and persons, to whom we aim to provide a targeted, affordable service that seeks to ensure export controls do not impede the ‘day to day’ core activity of sales. We can carry out licence applications on your behalf if required.

Which exports are controlled and therefore require a licence, how to apply and what compliance responsibilities you’ll have.

BExA Guide to Export Compliance

The British Exporters Association (BExA) has posted a free Guide to Export Compliance on its website.  The various chapters cover export control basics, financial compliance, customs compliance, supply chain compliance, and compliance culture in the company.

SPIRE overview

How to register on and use SPIRE, the online system for applying for an export licence for military or dual-use products

How to check if you need a licence to import or export goods, and the most commonly licensed goods for international trade.

Open general licences

Registering for an Open General Licence, information, guidance and advice on licences, which type you need for your goods.

Dual-use open general licences

Pre-published export licences relating to goods and technology that have both civil and military applications.

Dual-use licences: Cryptographic items – BIS / ECO

Cryptographic items subject to export controls are listed in Category 5 Part 2 of the European Union (EU) Dual-Use List.

Military Goods Open General Export Licences

Find out which Open General Export Licence you need for specific controlled military goods.

Other types of open general export licence

Details of open general export licences that don’t fit into other categories, but remove the need to apply for standard individual export licence.

European Union General Export Authorisations (EU GEAs)

European Union General Export Authorisations (EU GEAs) are the European equivalent of the national system of Open General Licences (OGLs) issued under UK export control law and are designed to licence dual-use exports.

Standard Individual Export Licence – BIS

You will need to apply for a SIEL if you need an export licence and you cannot meet all the stated terms and conditions of an Open General Export Licence (OGEL).

Open Individual Export Licence – BIS / ECO

Open Individual Export Licences allow exporters to export multiple shipments of specific goods to specific destinations.

Global Project Licence – BIS / ECO

A Global Project Licence (GPL) can be used when licensing exports of military goods and technologies to framework agreement (FA) partner states.

The UK Strategic Export Control Lists form the basis of determining whether any products, software or technology that you intend to export are ‘controlled’ and therefore require an export licence.

Export Licensing of Man-Portable Air Defence Systems – BIS / ECO

The UK applies strict national strategic export controls on exporting shoulder-launched surface-to-air missiles.

Firearms and export control forms – BIS

The UK – like many other countries – controls the movement (or export) of certain specified items to other countries, including to other EU destinations.

Find out if you need a strategic goods licence to export to the Channel Islands: how goods are listed on the UK Strategic Export Control Lists

If you are a UK company which exports controlled military goods to the United States you will need to comply with US controls, specifically the International Traffic in Arms Regulations (ITAR)

End-Use Control – BIS / ECO

How to judge which exports might potentially be of concern on end-use grounds.

Controls on dual-use goods – BIS

Exports of dual-use goods controlled by EU Dual-Use Regulation are wide ranging, encompassing goods in the telecoms, avionics and security sectors.

Controls on radioactive / nuclear sources – BIS / ECO

The scope of the Radioactive Sources (Control) Order 2006: which substances are controlled and how to apply for an export licence.

Controls on torture goods – BIS / ECO

Information on goods controlled under the EU Torture Regulation (including licensing of drugs used in execution by lethal injection).

Export Legislation

Why governments put trade controls in place, how they work for exporters, and how traders can apply for a licence.

Trade sanctions, arms embargoes, and other trade restrictions

Information on trade sanctions, arms embargoes and trade restrictions, including trade controls, transit controls and restrictions on terrorist organisations.

Department for International Trade and Export Control Joint Unit

Last updated: 18 February 2021

Contents

  1. Introduction
  2. Arms embargo, trade sanctions and other trade restrictions
  3. ECOWAS restrictions
  4. Non country-specific export policies and restrictions
  5. Restrictions applying to terrorist organisations
  6. Overlap between trade sanctions and strategic export controls
  7. Other non-trade-related restrictions
  8. Further information

Introduction

The UK uses sanctions to fulfil a range of purposes, including supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism. Sanctions measures include arms embargoes, trade sanctions and other trade restrictions.

The Foreign, Commonwealth & Development Office (FCDO) is responsible for overall UK policy on sanctions. The Department for International Trade (DIT) implements trade sanctions and other trade restrictions and has overall responsibility for trade sanctions licensing.

The UK implements a range of UK sanctions regimes through regulations established under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Sanctions Act provides the legal basis for the UK to impose, update and lift sanctions. These regimes apply to the whole of the UK, including Northern Ireland. It is your responsibility to ensure that you are compliant with the requirements of the new legislation.

For more information see the UK sanctions regimes under the Sanctions Act.

You can find out more about the UK sanctions policy after 31 December 2020.

DIT’s Export Control Joint Unit (ECJU) has overall responsibility for trade sanctions licensing. Licence applications can be made through the online export licensing system SPIRE. Certain trade-sanctions applications, for example, the purchase of petroleum products for humanitarian relief in Syria, are not processed on SPIRE and can be made by contacting tradesanctions@trade.gov.uk.

DIT’s import licensing branch is responsible for implementing trade sanctions relating to imports.

Arms embargo, trade sanctions and other trade restrictions

An arms embargo is a prohibition that applies to the trade or activities related to military items. An arms embargo may be imposed by the United Nations (UN), the Organisation for Security and Co-operation in Europe (OSCE) or the UK.

Under the Sanctions Act, arms embargoes consist of prohibitions on export, supply or delivery, making available and transfer of military items and on the provision of technical assistance, financial services and funds, and brokering services related to military items.

Trade sanctions are controls on:

  • the import, export, transfer, movement, making available and acquisition of goods and technology
  • the provision and procurement of services related to goods and technology
  • the provision and procurement of certain other non-financial services
  • the involvement of UK people in these activities.

There may be specific exceptions under which it is possible to engage in an activity that would otherwise be prohibited. It may also be possible to get a licence that would permit you to engage in an activity that would otherwise be prohibited.

Trade controls

The UK also imposes trade controls on trafficking and brokering of military goods from one overseas country to another. Trade controls apply to specific activities, including brokering, that involve certain controlled goods.

Goods which are subject to trade controls are specified in category A, category B and category C, of Schedule 1 to the Export Control Order 2008, as amended.

Article 20 of the Export Control Order 2008, as amended, sets out what trade controls apply in respect of embargoed destinations. Article 20 does not apply to countries with arms embargoes made under the Sanctions and Anti-Money Laundering Act 2018.

Transit controls

Certain goods transiting the UK are regarded as being exported when they leave the country and are subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception, meaning that in many situations a licence is not required.

This exception does not apply to certain goods destined for countries listed below, meaning that a licence is required to transit goods through the UK or tranship them in the UK with a view to re-exportation to these countries.

The Export Control Order 2008 includes a list of the countries which are subject to transit controls for military goods, and a list of countries which are subject to transit controls for Category B goods.

Military goods are those as listed in Schedule 2 to the Export Control Order. Category B of the controls comprises small arms and light weapons, unmanned aerial vehicles (UAVs), long-range missiles and man-portable air-defence systems.

Transit controls also apply to Category A goods for all countries.

ECOWAS restrictions

The Economic Community of West African States (ECOWAS) adopted a convention on small arms and light weapons, their ammunition and other related materials, and a moratorium on the import, export and manufacture of light weapons in June 2006.

The UK will not issue an export licence for small arms and light weapons, components or ammunition unless the ECOWAS Commission has issued an exception to its moratorium.

Countries subject to arms embargo, trade sanctions and other trade restrictions

This list details specific countries where arms embargo, trade sanctions and other trade restrictions have been imposed. This list does not include countries subject to only financial or other types of sanctions.

List of countries:

  • Afghanistan (trade sanctions including an arms embargo, and transit control)
  • Albania (transit control)
  • Argentina (trade restrictions and transit control)
  • Armenia (arms embargo, trade controls, and transit control)
  • Azerbaijan (arms embargo, trade controls, and transit control)
  • Belarus (trade sanctions including an arms embargo, and transit control)
  • Benin (ECOWAS restrictions and transit control)
  • Bosnia/Herzegovina (transit control)
  • Burkina Faso (ECOWAS restrictions and transit control)
  • Burma (Myanmar) (trade sanctions including an arms embargo, and transit control)
  • Burundi (transit control)
  • Cameroon (transit control)
  • Cape Verde (ECOWAS restrictions and transit control)
  • Central African Republic (trade sanctions including an arms embargo, and transit control)
  • Chad (transit control)
  • China (People’s Republic other than the Special Administrative Regions) (arms embargo and transit control)
  • Colombia (transit control)
  • Congo (Brazzaville) (transit control)
  • Côte d’Ivoire (Ivory Coast) (ECOWAS restrictions and transit control)
  • Democratic People’s Republic of Korea (trade sanctions including an arms embargo, and transit control)
  • Democratic Republic of the Congo (trade sanctions including an arms embargo, and transit control)
  • Dubai (transit control)
  • East Timor (Timor-Leste) (transit control)
  • Eritrea (transit control)
  • Ethiopia (transit control)
  • Gambia (ECOWAS restrictions and transit control)
  • Georgia (transit control)
  • Ghana (ECOWAS restrictions and transit control)
  • Guinea (ECOWAS restrictions and transit control)
  • Guinea-Bissau (ECOWAS restrictions and transit control)
  • Haiti (transit control)
  • Hong Kong Special Administrative Region (arms embargo and transit control)
  • Iran (relating to human rights) (trade sanctions including an arms embargo, and transit control)
  • Iran (relating to nuclear weapons) (trade sanctions (including an arms embargo) and transit control)
  • Iraq (trade sanctions including an arms embargo, and transit control)
  • Jamaica (transit control)
  • Kenya (transit control)
  • Krygyzstan (transit control)
  • Lebanon (trade sanctions including an arms embargo, and transit control)
  • Liberia (ECOWAS restrictions and transit control)
  • Libya (trade sanctions including an arms embargo, and transit control)
  • Macao Special Administrative Region (transit control)
  • Mali (ECOWAS restrictions and transit control)
  • Mauritania (transit control)
  • Moldova (transit control)
  • Montenegro (transit control)
  • Morocco (transit control)
  • Nepal (transit control)
  • Niger (ECOWAS restrictions and transit control)
  • Nigeria (ECOWAS restrictions and transit control)
  • Oman (transit control)
  • Pakistan (transit control)
  • Russia (trade sanctions including an arms embargo, and transit control)
  • Rwanda (transit control)
  • Senegal (ECOWAS restrictions and transit control)
  • Serbia (transit control)
  • Sierra Leone (ECOWAS restrictions and transit control)
  • Somalia (trade sanctions including an arms embargo, and transit control)
  • Sri Lanka (transit control)
  • South Sudan (trade sanctions including an arms embargo, and transit control)
  • Sudan (trade sanctions including an arms embargo, and transit control)
  • Syria (trade sanctions including an arms embargo, and transit control)
  • Taiwan (transit control)
  • Tajikistan (transit control)
  • Tanzania (transit control)
  • Togo (ECOWAS restrictions and transit control)
  • Trinidad & Tobago (transit control)
  • Turkmenistan (transit control)
  • Uganda (transit control)
  • Ukraine (trade sanctions and transit control)
  • Uzbekistan (transit control)
  • Venezuela (trade sanctions including an arms embargo, and transit control)
  • Yemen (trade sanctions including an arms embargo, and transit control)
  • Zimbabwe (trade sanctions including an arms embargo, and transit control)

Non country-specific export policies and restrictions

You need an export licence before you can export controlled goods, software, and technology from the UK to another country. This is described in Schedules 2 and 3 to the Export Control Order 2008, as amended.

For further information you can read about licensing procedures and other restrictions for the export of:

Restrictions applying to terrorist organisations

The UN Security Council has imposed measures against terrorist organisations in relation to financial and visa sanctions, and arms embargoes.

For more information on these restrictions, you can read about sanctions on:

Overlap between trade sanctions and strategic export controls

Military goods and technology

Please note that the export of and other trade in military goods and technology is controlled under sanctions regulations and the Export Control Order 2008, and so you may need a licence which is valid under both pieces of legislation.

This means that all licence applications relating to military goods and technology will need to be considered against the sanctions licensing purposes, and the strategic export licensing criteria. A licence under sanctions regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.

The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the sanctions regulations and the Export Control Order 2008 as an application under both pieces of legislation.

This means that only a single licence application is required. The application will be considered against the relevant licensing criteria. If a licence is granted, it will be valid under both the Export Control Order 2008 and the sanctions regulations.

Breaching trade sanctions and export controls is a criminal offence. Find information on how to report a breach of trade sanctions.

Overlap between trade sanctions and financial sanctions

If you trade in goods or services, you need to consider if financial sanctions apply to you. For instance, where your licensable trade activity may also involve making funds or an economic resource available to, or for the benefit of, a designated person.

The Office of Financial Sanctions Implementation (OFSI) is responsible for the implementation and administration of international financial sanctions in the UK. You may need a licence from OFSI as well as from the Export Control Joint Unit.

Other non-trade-related restrictions

There are various non-trade-related restrictions in force which relate to UK exports, such as immigration sanctions, financial sanctions. The FCDO is responsible for overall UK policy on international sanctions. You can find information on other types of sanctions on the UK sanctions guidance page.

Further information

For general guidance on export controls and trade sanctions, contact the Export Control Joint Unit (ECJU):

Email: exportcontrol.help@trade.gov.uk Helpline: +44 (0)20 7215 4594

To receive latest updates about arms embargoes and changes to strategic export control legislation, subscribe to the Export Control Joint Unit’s Notices to Exporters.

For general guidance on import controls and trade sanctions contact: importcontrols@trade.gov.uk

For general information on sanctions email the Foreign, Commonwealth and Development Office’s Sanctions Unit on: sanctions@fcdo.gov.uk

For information on financial sanctions, contact the Office of Financial Sanctions Implementation on OFSI@hmtreasury.gov.uk or subscribe to OFSI’s e-alerts.

For further information on immigration sanctions: contact the Home Office on public.enquiries@homeoffice.gov.uk

Trade Controls and Brokering – BIS / ECO

You need a Trade Control Licence if you transfer controlled (military or dual-use) goods between one overseas country and another.

Transhipment licences

Transhipment licences allow controlled goods to pass through the UK on the way to other destinations: find out when you need one and how to use it.

Export control legislation for UK academics and researchers

Members of the UK academic community may need an export licence if they are sharing technical information with colleagues in other countries or dealing with other controlled items.

Export of technology

Export licensing for exporters of controlled technology (ie information used to make controlled goods such as weapons).

Electronic transfer abroad of controlled military technology and software – BIS / ECO

UK export controls on technology make specific provision for electronic transfer of military technology.

Crown exemption for controlled military list equipment and technology owned by the UK MOD

This guidance provides a brief overview about Crown exemption in respect of the transfers of export controlled military list goods or technology owned by the UK Ministry of Defence (MOD).

Exporting in support of UK government defence contracts

Goods in support of UK government defence contracts that require an export licence and use of the Open General Export Licence

MOD form 680 applications – MOD / BIS

The Ministry of Defence Form 680 is used by government to consider the release by companies of equipment or information (including technology or software) classified ‘Official-Sensitive’ or above (including UK material classified ‘Restricted’ or above, graded prior to 2 April 2014, and internationally security classified material) to foreign entities.

Strategic Export Controls: Reports and Statistics (licensing decisions) – BIS / FCDO

This website contains data on export licensing decisions which has historically been published as read only in the quarterly and annual reports.

FCDO’s Strategic Export Controls Reports

The Foreign, Commonwealth and Development Office’s Strategic Export Controls Reports demonstrate the Government’s commitment to transparent and responsible…

Government Departments

Export Control Organisation (ECO)

The Export Control Organisation (ECO) issues licences for controlling the export of strategic goods.

Society for International Affairs

SIA interests cover the entire spectrum of licensing issues pertaining to the Department of Commerce, Defense, State and Treasury