Dual-use goods

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Glossary · Sanctions

Dual-use goods

Also called dual-use items, dual-use technology

Definition

Dual-use goods are items, software and technology with both civilian and military uses, such as certain chips, machine tools, chemicals and drones. Their export is controlled. Exporters need a licence for listed items and some destinations. Banks financing trade check for dual-use risk because these goods are a common route for sanctions evasion.

CIVIL USEMILITARY USE
Fig. 1 · Dual-use goods
EU Dual-Use Regulation · Russia dual-use ban · Export Control Order 2008
Key rulesEU Dual-Use Regulation · Russia dual-use ban · Export Control Order 2008
Applies toExporters, brokers and technical assistance providers in the EU
RegionsEU · UK · US · Global
01

How it works

Control lists set out which items are dual-use, largely based on multilateral regimes such as the Wassenaar Arrangement. An exporter classifies each item against the list. If it is controlled, the exporter applies for a licence before shipping. Banks see the trade through letters of credit and payments, and screen goods descriptions, codes, end users and routes for red flags such as transhipment hubs.

Military programmes rely on imported civilian components. The EU, UK and US ban most dual-use exports to Russia and have published lists of high-priority items found in Russian weapons. Diversion through third countries is a known evasion pattern.

Step 1ClassifyMatch goods to control list entries.
Step 2Check end useConfirm the end user and final destination.
Step 3LicenseObtain an export licence where required.
Step 4Screen tradeBanks review documents and routes for red flags.
02

The rules

EU · 9 September 2021EU Dual-Use RegulationRegulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items

Requires authorisation to export listed dual-use items and allows controls on unlisted items linked to weapons or human rights abuse.

Exporters, brokers and technical assistance providers in the EU
EU · 25 February 2022Russia dual-use banCouncil Regulation (EU) No 833/2014, Article 2, as replaced by Council Regulation (EU) 2022/328

Prohibits selling, supplying, transferring or exporting dual-use goods and technology to any person in Russia or for use in Russia.

EU persons and entities
UK · 6 April 2009Export Control Order 2008Export Control Order 2008 (SI 2008/3231)

Sets UK licensing for military and dual-use exports alongside the retained dual-use regulation.

UK exporters
03

Common questions

Why do banks care about dual-use goods?

Banks financing or paying for trade can facilitate sanctions breaches. Dual-use goods are a main channel for supplying sanctioned military programmes, so banks screen trade documents, goods and counterparties.

What makes a good dual-use?

Its technical specifications. Control lists define items by performance, such as processor speed or machining precision. Ordinary consumer versions often fall below the thresholds, while high-performance versions need a licence.

Can an unlisted item still need a licence?

Yes. Catch-all controls apply where an exporter knows or is told that goods are intended for weapons of mass destruction, military end use in an embargoed country or similar uses.