Trade Control Training

Project Alpha at King’s College London offers modular training on trade control issues related to the topics of dual-use goods, sanctions compliance and open-source intelligence research. In addition to the modules set out below, custom modules can be developed for particular clients. Courses can be custom built and last from half a day to five days, with each module taking around half a day (3 hours) to a full day to deliver, including practical exercises. Depending on the modules chosen, appropriate materials are provided for participants, such as handbooks, reading materials, tools, guides and reports.

This training is tailored for private sector companies, research and academic institutions, and government officials involved in the trade compliance field. Some modules include training on open-source intelligence research tools and techniques, which are useful in the context of conducting due diligence.

Contact Ian Stewart (ian.stewart@kcl.ac.uk) for more information.

Module 1:      Introduction to Trade Compliance

This module is aimed at staff who are new to trade control issues and to present a macro-level understanding of the strategic implications of trade non-compliance.

This module will be specifically tailored based upon the company’s sector and relevant jurisdictions:

  • Key trade compliance requirements;
  • Key regulatory bodies;
  • Regulatory penalties and enforcement actions;
  • Compliance requirements in practical terms;
  • Benchmarking a company’s compliance against others in the sector.

Module 2:      Introduction to the Dual-Use Trade Control Framework

This module introduces the international framework and key concepts involved in dual-use export controls, and works to develop practitioners’ in-depth understanding of dual-use trade controls. Elements covered include:

  • Non-proliferation international legal instruments (ie. UNSCR 1540, key sanctions resolutions);
  • Multilateral Export Control Regimes – their development and current structure, membership, decision-making procedures (NSG, Zangger Committee, MTCR, Australia Group, Wassenaar Arrangement);
  • Key national and regional export control models (US, European Union);
  • Key concepts and definitions: catch-all, intangible technology controls, brokering, trans-shipment, dual-use, proliferation finance (with examples and case studies).

Module 3:      Dual-Use Controls in Practice

 This module is intended to provide a more detailed introduction to control lists and to commodity identification. The module will examine selected items drawn from across the control list but can be tailored to the needs of participants. It is delivered by engineers who have expertise with control lists and will include technical discussions of specific items. This module will also explain the origin of control lists, how they are compiled, and how they are used in export control implementation and compliance, specific to the trainees’ jurisdiction:

  • Control list compilation process and item classification;
  • Tools and resources for understanding and tracking items;
  • End-use and end-user verification (techniques, red flags, follow-up); post-shipment verification;
  • Licensing in practice;
  • Inter-agency cooperation;

Module 4:      Control List Ratings – Practical Examples

This module involves the rating of actual controlled (and in some cases non-controlled goods). Two approaches are taken. The first is based on items. The second based upon technical specifications. In both scenarios, participants learn to examine and compare the technical characteristics of the items with the control list.

Module 5:      Financial Sector Compliance 

This component applies the concepts and issues discussed in the previous days of the course in the industry context, including how to create and reinforce a culture of compliance:

  • Financial sector compliance;
  • Internal compliance programmes – components;
  • Tools, resources and red flags for end-use and end-user verification;
  • Financial sector suspicious indicators;
  • Cooperation with regulatory agencies;
  • Good practices;
  • Writing Suspicious Activity Reports.

Module 6:  Entity Screening

 

Entity screening has become a central aspect of trade controls in recent decades, with many governments publishing lists of ‘designated’ entities with whom trade is in some way restricted. It is vital for all companies to screen against at least relevant national lists.  This module contains the following elements:

  • Overview of relevant lists and of relevant regulatory reach (i.e. extraterritorial);
  • Examination of principles of screening, including accuracy;
  • Comparison of tools for entity screening;
  • Live examples utilising the Alpha-POST system.

Module 7:  Non-proliferation Trade Controls for the Financial Sector in Action: Cases

This module will present case studies regarding how the financial sector has been involved in cases of proliferation finance. It will also present research tools and techniques that professionals can use to mitigate risk.

  • Methods and instruments commonly used;
  • Trends and developments;
  • Open-source techniques;
  • Case studies: Dual-use;
  • Case studies: Sanctions circumvention.

Module 8:  Intangible Technology and Deemed Export Control

While much attention is given to the export of physical goods, governments also control ‘intangibles’ associated with controlled items. The purpose of this module is to describe intangible technology controls by:

  • Examining the definitions of technology in relevant countries;
  • Examining the exemptions in relevant countries (i.e. information in the public domain and intangible technology controls);
  • Examining specific examples of technology to determine whether it is controlled.

Module 9: Trade Controls in Academia

This module examines the issue of trade compliance in academic institutions and research centres. The module is based primarily upon a guide that KCL developed for UK universities in partnership with the Association of University Legal Practitioners and UK government departments (available online here: projectalpha.eu/academia). The module is intended both for university administrative and academic staff and for company staff who might contract with universities for research. The module covers:

  • Introduction to export controls in the academic environment;
  • Requirements of export controls and sanctions;
  • Exemptions (public domain and basic scientific research);
  • A study of trade control in academia through case studies.

Modules 10 and 11: Open Source Intelligence and Corporate Due Diligence (Double Module)

This module is intended for company staff who are involved using open-source intelligence for due diligence activities. The module draws upon materials and tools developed by KCL for open source intelligence activities but is tailored to due diligence work. An open-source intelligence handbook is included in this module.

The first module covers:

  • Principles of open-source intelligence;
  • Introduction to open source intelligence tools and techniques;
  • Considerations around the use of OSINT (evidentiary, legal, ethical);
  • Open source analysis.

The second module covers practical examples of open-source intelligence research in practice. This module thus requires participants to have access to PCs. Areas covered include:

  • Advanced internet search techniques;
  • Data mining;
  • Entity profiling;
  • Geolocation;
  • Introduction to advanced tools: the Alpha-POST Platform and APIs

Note: Other training on open-source intelligence is available from KCL.

Improving the implementation of non-proliferation controls