The Export Control (Amendment) (No. 2) Order 2019 (SI 2019/1159) amends the principle instrument of UK export control, the Export Control Order 2008, to insert a new dual-use control in respect of submersible vehicles prohibiting the export and transfer of such goods and software or technology for the development, production or use of such goods where they are destined for Russia.  This is national control measure, said to be a direct consequence of Russia’s development of unconventional warfare equipment and capabilities.  Russia has been active in tracking undersea communication cables, which carry the bulk of the world’s telecommunications data, and this activity could pose a potential threat to UK national security and prosperity given its dependence on this infrastructure.  A new entry on the control lists includes the equipment that would help Russia develop, operate and maintain its capability, thereby posing a risk to national security, in particular subsea communication cables.  This new control means all exports of this equipment to Russia are prohibited unless a licence is granted.  It therefore allows the UK to control the export and transfer of such goods, software and technology where it is for the development, production or use of such goods, where they are destined for Russia.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: