ANALYSIS OF END-USER DOCUMENTATION RELATING TO THE TRANSFER OF CONVENTIONAL WEAPONS AND AMMUNITION

In August, the Conflict Armaments Research body published the latest edition of its Diversion Digest which contains an analysis of end-user documentation held in its archive.  It says that a comprehensive and detailed end-user document should provide an export licensing authority with information that would form the bedrock of its diversion risk assessment.  The documentation is end-user certificates (EUC) and certified end-user statements (EUS).

An EUC is an official document, issued by a competent authority of the importing State, that identifies a government agency of the importing State as the ultimate recipient of an international transfer of small arms or light weapons.  A certified EUS is a document issued by a private end-user that provides assurances regarding the end user and end-use of internationally transferred small arms or light weapons [and] that has been stamped and signed (or otherwise certified) by a competent authority of the importing state.  However, there is a lack of international consensus regarding the structure and scope of end-user documentation. Documents are not standardised across exporting or importing authorities, and differences in national systems and definitions pose a challenge to supply-chain control.

The key findings of the analysis is the lack of standardisation; the absence of key information, such as an expiry date and/or provide only vague descriptions of the end-use/user (e.g. just “the government”); inconsistent re-export clauses, where these exist; limited delivery verification and/or post-shipment controls; and red flags that included omitted or redacted important information, poorly completed documentation or (in one case) 2 separate documents bearing the same “unique” reference number(!).

https://www.conflictarm.com/digests/diversion-digest-issue-2/

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 https://www.buymeacoffee.com/KoIvM842y

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

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