Screening goods of proliferation concern and their means of delivery

Alongside financial sanctions, the government imposes controls on certain types of trade. As part of this, the export of goods and services for use in nuclear, radiological, chemical or biological weapons programmes is subject to strict controls.

Some sanctions breaching activity, particularly Proliferation Finance activity, is not just about the acquisition or purchase of a controlled good or service. In many cases sanctions breaching activity has the sole aim of generating access to foreign currency and the international financial system. This can be through what appears to be a legitimate trading entity. For this reason, it is important to understand the full payment chain and consider how any trade may be used to enable illicit activity. Some vessels also are designated and are financial sanctions targets.

You can assess your goods, software and technology against the UK Strategic Export Control Lists to determine whether they are controlled. The designated vessels list can be obtained from the UK Sanctions List.

The OGEL and Goods Checker Tools can be used to

• check if the items are controlled;
• identify the appropriate control entry.

Examples of good and poor practice include:

Good practice	Poor practice
Ensuring staff are aware of dual-use goods issues, common types of goods that have a dual use, and are capable of identifying red flags that suggest that dual-use goods risk being supplied for illicit purposes	No clear dual-use goods policy
Confirming with the exporter in higher risk situations whether a government licence is required for the transaction and seeking a copy of the licence where required.	Failure to undertake further research where goods descriptions are unclear or vague
	Third party data sources are not used where possible to undertake checks on dual-use goods.

 

Recommended self-assessment questions:
Who and where the goods or services are coming from or going to. It is possible that financial sanctions such as an asset freeze may apply to one of the parties or to the financial aspects of the trade.
Who is shipping the goods, and whether they are being shipped on a sanctioned vessel
Whether a designated person is based in a different country to the one you are operating in, but is still subject to financial sanctions in that country.

 

Screening goods is only one part of PF mitigation. Proliferation financing often involves legitimate-looking transactions, front companies, and complex payment chains. Controls should address these risks beyond goods screening. For more detailed Guidance please refer to our guidance on countering the proliferation of weapons of mass destruction (WMD) and their financing.