Category Archives: Initiatives

Study of the Typologies of the Financing of Proliferation (STFoP)

 

The proliferation of weapons of mass destruction (WMD) is a major threat to international peace and security. Detecting the financing of proliferation (FoP) can assist in combating WMD, but it is difficult and requires a better understanding of FoP typologies. Typologies can assist governments in implementing sanctions on WMD programs and disrupting proliferation networks. They can also help the private sector to identify information on FoP that should be passed to governments, and to remain compliant with sanctions. Continue reading Study of the Typologies of the Financing of Proliferation (STFoP)

Enhancing ties: the India-UK Strategic Nuclear Dialogue

Participants to the first leg of the India-UK Strategic Nuclear Dialogue held in London UK.
Participants to the first leg of the India-UK Strategic Nuclear Dialogue held in London UK.

To explore ways to strengthen the partnership between the UK and India on strategic nuclear issues, Project Alpha of King’s College London, together with the Institute of Defence Studies and Analyses (IDSA) in India organised a two-leg dialogue during the first quarter of 2016. The sessions were attended by scholars, practitioners and officials from the two countries, who explored a number of relevant topics in order to build common understanding and identify opportunities to further strengthen the relationship between the UK and India.

The first event, held at the Royal Society for the Arts in London on January 18th to 19th 2016, focused on common interests and areas for collaboration, strategic challenges and stabilities, non-proliferation and disarmament efforts, as well as India’s entry into the export control regimes.  The second event was held at the IDSA office in Delhi on March 1st to 2nd 2016, where the discussion focused on the Asian security landscape, export control governance, and discussion on the next steps to developing the India-UK alliance.

The detailed meeting summary of the event can be accessed below.

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Alpha Trade Management Database: a new tool to help companies monitor exposure to dual-use goods

Project Alpha is pleased to introduce Alpha-TMD : a new tool to help monitor corporate exposure to restricted dual-use goods.

Global sanctions measures against countries like Iran and North Korea make it essential for firms to monitor their exposure to trade involving dual-use goods and technology: those items that can be used for legitimate industrial purposes, but could also contribute to building weapons of mass destruction (WMD). Ignoring international restrictions on the supply and brokering of dual-use goods can lead to hefty penalties, not to mention the reputational damage that comes from assisting WMD proliferation.

But monitoring trade and financial systems for dual-use technology of WMD concern is not easy. The technology control lists mandated by multilateral organisations like the Nuclear Suppliers Group are fragmented, highly-technical in nature and often unstructured. Moreover, they are not easily compatible with systems used in the anti-money laundering and due diligence context.

To help companies overcome these hurdles, Project Alpha has created Alpha-TMD (Trade Monitoring Database), a structured database of controlled dual-use technology. Alpha-TMD has collated all of the chemicals, materials and technologies controlled under the main dual-use technology export control regimes (the Nuclear Suppliers Group, the Missile Technology Control Regime, the Chemical Weapons Convention, and the Australia Group) – more than 600 dual-use items in total.

Each dual-use item in Alpha-TMD is listed with the following information:

–          Control regime status;

–          Item description or rationale for control;

–          Keywords to identify controlled technology, each developed by Project Alpha experts;

–          ‘Not’ keywords and Boolean search terms to reduce false positives;

–          Chemical Abstracts Service (CAS) reference numbers for chemicals and metals;

–          A qualitative assessment of each item’s broader industrial utility beyond the WMD context (low, medium or high), to help companies decide whether to regulate or block trade in these items.

We believe that Alpha-TMD can help companies working in the trade, shipping and financial space maintain their compliance obligations with respect to trade in dual-use goods, and would be pleased to discuss its pricing and availability.

Please contact Ian Stewart (ian.stewart@kcl.ac.uk) for further information.

EU Summer University on Non-proliferation and Export Controls

King’s College London partnered with the European Commission to host the European Union’s Summer University on Non-proliferation and Export Controls from 18th to the 24th August in Alpbach, Austria.

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Summer university participants

This was the first summer university funded by the EU’s outreach program on dual-use goods, which works to build capacity to implement non-proliferation controls in more than two dozen countries outside of Europe. The University included government participants from more than 20 countries, including China, India, UAE, Ukraine, and Vietnam.

Guest speakers also presented on the export control systems of India, Malaysia, Belgium and the USA.

The core topics for the university were related to export control and non-proliferation, including more the more challenging topics from these fields, such as intangible technology controls. The participants also heard from UN Undersecretary General and UN High Representitive for Disarmament Affairs,  Angela Kane, on the effort to destroy Syria’s chemical weapons; from the EU’s ambassador to the UN Thomas Mayr-Harting; and from Alexander Kment on the humanitarian initiative related to nuclear weapons.

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A summer university seminar in action.

Several students passed the course with distinction and two students – Mr Wu of China and Ms Bagrii of Ukraine – were recognised for their particularly impressive performance in the end of course exam. Mr Fischler, the president of the Alpbach Forum, presented the certificates to the participants.

The event was the first EU outreach event related to dual-use goods that King’s College London has participated in. From 1 September 2015, King’s college London will partner with Expertise France to implement the EU outreach program on dual-use goods, through which more focused training and assistance will be provided to the partner countries in relation to the implementation of dual-use export controls.

More information on the EU outreach program on dual-use goods can be found at: https://export-control.jrc.ec.europa.eu/

Project Alpha and the Iran Deal

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Image credit: Islamic Republic News Agency

Project Alpha is pleased to make available a wide range of resources on Iran. This includes detailed analysis of the 14 July 2015 Joint Comprehensive Plan of Action (and its implementation) and analysis of Iranian illicit procurement. It also includes information, guidance and training for companies on trade compliance issues.


Project Alpha’s Work Related to the Joint Comprehensive Plan of Action with Iran (the Iran Deal)

Project Alpha Proliferation Case Study Series:

Other work on Iran:

Project Alpha is a semi-autonomous project in the the Centre for Science and Security Studies at King’s College London. Additional resources on the Iranian nuclear challenge produced by CSSS can be found here.

Project Alpha and Association of University Legal Practitioners issue export control guidance for academia

Project Alpha and the Association of University Legal Practitioners are pleased to release today a guidance document for universities and the higher education sector on export controls and the UK Government’s student vetting scheme (ATAS).


This document has been prepared with support from the UK’s Export Control Organisation and the Foreign and Commonwealth Office. The purpose of the document is to provide a comprehensive yet accessible guide for university practitioners on the export control legislation applicable in the UK and the Academic Technology Approval Scheme (Student Vetting Scheme) which are separate but complementary regimes. This document also contains tools prepared by Project Alpha and AULP members, including policy statements, flowcharts and questionnaires, that can be used by university staff to determine if those controls affect them and how to manage compliance. No specific change in legislation or policy prompted the preparation of this guide.

Who is this document for?

This Guide is specifically targeted at university vice chancellors, legal and compliance departments, research support teams and technology transfer offices. It includes suggested templates for working with individual academics and researchers involved in academic disciplines affected by non-proliferation-related controls, particularly engineering and science fields since it is these areas that are most likely, but not exclusively, to be affected by Export Controls.

Ideally, awareness and guidance on Export Controls should form an integral part of an academic institution’s research policies and guidance on good practice in research.

Context Controls over strategic goods or technology (collectively referred to as “Export Controls”) have been enacted in the UK for decades, with weapons of mass destruction (WMD) provisions in relation to transfers of technology or technical assistance being in place from at least 2004. Equally all EU countries are required to maintain a system of end-use export and transfer controls. By international law, all countries which are members of the UN have been required since 2004 to maintain a system of Export Controls in order to prevent the proliferation of weapons of mass destruction. This requirement affects not just commercial entities, but applies to all entities (commercial or non-commercial) including universities and researchers that might ‘export’.

The collective implications of these commitments and obligations is that in some cases individual academics in a university may need an export licence from the Export Control Organisation to carry out an activity – failure to obtain one being a criminal offence.

 NOTE: This document is for guidance only. It is NOT a statement of law. Before carrying out any activity subject to strategic controls (exports, transfers of technology, provision of technical assistance, etc.) you should refer to the legal provisions in force at the time.

The Tool Kit:

A Decision Tree adapted for local circumstances would help academics make an initial assessment about whether the rules apply and what needs to be done. An institution’s decision tree might be along the following lines:

If you answer “yes” to any of the following questions, take advice:-

Question 1) Was the technology imported from the US? Universities should be aware that in some instances controls from other territories may apply in addition to UK-administered controls. This is particularly common for US technologies, where re-export clauses often apply which prevent not only the goods, software or technology being re-exported to particular countries, but also can prevent it being transferred to or shared with foreign nationals within the UK.

If the technology is subject to ITAR or EAR this may affect exporting and also sharing with researchers within the institution who are from overseas or have dual nationality. These rules need to be satisfied, as well as UK export control requirements. But do not forget to consider UK Export Controls also.

Question 2) The Technology: The primary question that must be answered is whether it appears on the Export Control list. The ECO offers a range of services to help with the process of classification to determine whether the technology is listed. There are three key points to establish here:

Firstly: Is the item or technology specifically designed for military or nuclear end uses?

Secondly: Does the export include encryption software or hardware?

Finally: Do you need to check the UK controlled list of military or dual use items?

Question 3) End use controls: Who are you working with?

The end use controls look at who the end user is and what the end use is. The following list of questions may help you establish an end use or end user issue that you need to look into further.

Even if the item, technology or software is not listed in the UK Consolidated Lists, a licence could also be required if the exporter knows, has been informed or suspects there is a WMD end use.

Question 4) Sanctions

Additional restrictions can apply when dealing with countries that are subject to sanction. These can include restrictions on the actions of individuals and entities, including their ability to travel or to use financial systems, and they can include additional restrictions on exports or trade activities, which often have the effect of broadening the UK Consolidated Lists to include items which would not normally be included in the UK Consolidated List.

Two flow charts are offered:

1. Basic awareness – to help researchers understand if they need to know more about Export Control. (Note: This flowchart does not ask researchers whether their goods are controlled. It is intended for use as an awareness raising tool only.)

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2. When do the UK Consolidated Lists need to be considered?

This second flow chart on the following page links and cross references to the proposed Decision Tree. “Controlled” as used in this flow chart means the technology is on either

• The Consolidated Military and Dual Use Lists or

• Any Sanctions List

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The document can be downloaded at the link below.

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Global trade sanctions and the freight forwarding industry: Implementing compliance good practices in the face of changing requirements

Global sanctions regimes

  • The direction of growth of global commerce is greatly influenced by international sanctions and control regimes. These change constantly in response to geopolitical or other developments.  International agreements for example may include provisions for targeted and phased lifting of sanctions over lengthy periods (this is likely to be the case for any long-term agreement between Iran and the P5+1). To maintain a competitive edge in such an environment, companies in freight forwarding and related industries need a smart and adaptive approach to compliance.

Continue reading Global trade sanctions and the freight forwarding industry: Implementing compliance good practices in the face of changing requirements