Published on April 18, 2014
Introduction GREEN LIGHT EXPORTS CONSULTING 1
What We Offer If you are expanding your exports to emerging markets, we can help – to clarify - for your specific products, to specific markets - what is and isn’t possible within embargoes and other constraints to avoid delay or denial of an F680 or export licence to factor in political and reputational risks In any of the emerging markets – Middle East, Africa, Asia, Latin America 2
Defence spend is contracting in mature markets, expanding in emerging markets Source: SIPRI 3
Emerging markets = opportunities + risks 4
‘Catch 22’ How can exporters of sensitive goods be sure their exports will not breach sanctions, not be refused a licence, or not pose major reputational risks? You can only know if you will get a licence if you first get a contract. How can you find out earlier? (NB F680s do not indicate whether a licence will be granted) If you export sensitive goods but do not need a licence, how do you assess the risks? We can help. 5
Arms Embargoes, Sanctions, Asset Freezes, Treaty Obligations We can clarify what you can sell to whom, and what you can’t. We also look ahead at the prospect of changes to existing regimes. 6
Human Rights, Internal Repression and International Humanitarian Law Neither HMG nor you want your goods associated with repression. We advise on the risks, now and in the future. SOURCE:wikimedia.com 7
SOURCE:wordpress.com Will your export provoke or prolong internal or regional tensions or conflicts? If so, it will not be permitted. We can advise. 8
What is the risk of your equipment or technology being used against UK or allied forces? 9
… or being diverted to an undesirable end-user? 10
We can help navigate the UK trade licensing process Applicant (application) Licence Reception Licensing Unit Licensing Unit Applicant (RFIs) Enforcement Unit Other Government Departments (OGD) Advisors DECC CWC NSG DfID CHSD Posts GCHQ CESG MOD Licence Issued OIEL REJECTE D Apply for SIELs Applicant (exports) Technical Assessment Unit ECO Compliance Unit Visit OIEL Suspended Applicant (RFIs) Report to ECO via Spire FCO CPD AEPT Posts 11
… and the MOD F680 process EXPORTER MOD ACP Capability Protection Def Sy (Sc & Tech) FCO AEPD ELT, IOD, SecPol HRDGG, Posts Defence Intelligence Staff DFID 12
13 … and avoid delays with applications Query Cause(s) EUU EUU and ELA contain contradictory information. The EUU is out of date, unsigned or is signed by multiple parties. It’s not possible to determine who signed the EUU (no letter head). EUU contains an electronic signature. Tech Specs. The technical information does not include the relevant assessment parameters from the related control entry. Goods Descriptions The goods description should describe the goods, not their design origin or purpose. Third Parties There are third parties / ultimate end users listed on the EUU that are not listed on the application. Incorporation Knowing when your consignee is your end user because they are incorporating or integrating your goods.
We look in detail at equipment/end-user combinations Nigeria: CT/Surveillance Equipment All applications to export equipment that could be linked to the arrest and subsequent mistreatment of suspects, such as mobile phone tracking equipment, will be subject to close scrutiny. HMG has not recently authorised the permanent export of any lethal equipment to the Nigerian Armed Forces or Police. There are specific concerns surrounding the use of surveillance equipment, such as that used for mobile phone interception, by the Nigerian authorities including the Department of State Services (the State Security Services) HMG will look closely at the potential proximity of such equipment to allegations of mistreatment in detention centres and whether that equipment is sufficiently linked to the mistreatment of those incarcerated if it is used during arrest and detention procedures approval of equipment for direct use in CT operations in Nigeria would be highly unlikely under the present circumstances 14
We analyse the reasons for past export licence refusals (2013 figures) 0 50 100 150 200 250 TOTAL 8 – Economic capacity of… 7 - Risk of diversion 6 – Behaviour of buyer country 5 – UK National security 4 – Regional instability 3 – Internal tensions or conflict 2 – Internal repression 1 - Embargoes/Treaties 15
We cover all emerging markets 16
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Introduction. green light exports consulting. What We Offer. ... How can exporters of sensitive goods be sure their exports will not breach sanctions, ...
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