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International supply of military goods

UK’s ‘Brokering’ controls

This is our specialty and with our unique background in this field for the UK government, we are unaware of any consultant with greater experience and knowledge of said controls

These controls require UK persons and those within the UK, to obtain a [Trade] licence if they wish to arrange the transfer of military list goods from one third country to another.

The UK controls (Export Control Order 2008) provide details of those goods of greater concern to the UK government.

http://www.legislation.gov.uk/uksi/2008/3231/schedule/1/made

 

The remainder of the list of controlled goods is within Schedule 2 of that order

So, if you are involved in arranging the transfer and in some circumstances, merely general advertising and promotion (for example placing advertisements), finance, financial services, insurance or reinsurance services or contract promotion activity of the international transfer of goods on the UK Military list, you may need a Trade licence.

Failure to obtain a licence when required can lead to up to 10 years in jail

 The rules apply to UK nationals whether they have right of abode in the UK or not. They apply whether the UK national is working for a UK company, for a non-UK company or for themselves

In addition, there are arms embargoes, which change frequently , Financial  sanctions and the Bribery Act.

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The Export control order 2008 says :-

Extract from the order:

1) This article applies to— (a)persons carrying out activities in the United Kingdom; and

(b)United Kingdom persons.

2) Subject to articles 25 and 26, no person to whom this article applies shall directly or indirectly—

(a)supply or deliver;

(b)agree to supply or deliver; or

(c)do any act calculated to promote the supply or delivery of

any goods subject to trade controls from one third country to another third country

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There are different requirements placed on you depending on

1/ the nature of the goods being supplied – as stated they must be on the UK military list (which includes paramilitary equipment such as Tazers)

2/ The end user of the goods e.g. are they subject to any restriction/embargo ?

3/ the part played, as some subsections exclude Financial and transportation services.

So, by way of example

  • if a UK airline/shipping line, shipped military goods to a location subject to a UK embargo  or transhipped small arms/light weapons through the UK

  • If one Insured a shipment of ‘Tazers’ from US to New Zealand; ( we were involved is assisting Lloyds of London with their guidance under Project Brass)

  • Whist providing training overseas, you supplied military list equipment to your trainers or trainees

  • You supplied your Security or PMC personnel with military list equipment.

  • Bomb disposal suits and CIED equipment to trainers or practitioners not exported directly from the UK

  • arranging or negotiating contracts

  • arranging or providing freight or transport services

  • arranging intra company transfers

  • introducing third parties for an ‘arms’ deal for a fee.

  • a Banker providing a Letter of Credit for a transfer

 

 

If in doubt, please contact us via our Contact page

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