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(!).

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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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