Export controls can control not only the export of physical goods, but also the ‘intangibles’ associated with controlled items. Continue reading Can’t touch it, can’t see it? It’s still subject to export controls.
At least five Iranian companies designated by the European Union and other sanctions regimes for supporting Iran’s nuclear programme are advertising as suppliers on the NYSE-listed Alibaba Group’s Internet trading platform alibaba.com, Project Alpha has discovered. Continue reading Alibaba’s compliance challenge, part II: Iranian nuclear procurers
This paper considers how to strengthen United Nations Security Council sanctions which have been imposed on States that sponsor proliferation. Continue reading Strengthening UN sanctions on proliferators – lessons from the UN Panels of Experts
Alpha has spent a great deal of time working with manufacturers and exporters of proliferation-sensitive goods in order to reduce the risks that their products will reach programmes of concern. This work is important – for example, see the recent case study involving MKS instruments. However, it is not only goods that are shipped from a factory that present proliferation risks: goods sold via distributors and second hand items can also. Continue reading Procurement of Pressure Transducer via Ebay From China
Li Fang Wei and LIMMT
In 2009, Li Fang Wei and his Dalian (China) based LIMMT trading company were indicted by a court in New York (USA) on 118 counts of falsifying business records in order to use US financial institutions to receive payments for proliferation-sensitive goods transferred to Iran and other locations. This procurement case study seeks to provide industry with a concise example of the forms that illicit procurement can take. Continue reading Li Fang Wei and LIMMT
The government of Switzerland has prevented the export of ski lifts to North Korea. The Swiss government is believed to have taken this decision in line with the UN Security Council resolutions prohibition on the import of Luxury goods. Continue reading North Korea Sanctions: Swiss Government Prevents Ski Lift Sale
Illicit Procurement of a Fluid Control Product
· The robustness of the export compliance systems of distributors is key to preventing proliferation. The lack of awareness held by the stockist about export licensing requirements was shocking; it was Company C’s reputation at risk too.
· Buyers may pursue products with a lower technical specification if it might mean that they can avoid the control list. Companies should be fully aware of their products potential uses and full end-user checks should be carried out to mitigate this risk.
During the cold war, the Soviet Union engaged in a highly organised and sustained effort to procure sensitive technologies from abroad to advance its conventional military programmes. This procurement case study seeks to draw lessons from the Toshiba-Kongsberg case to highlight the financial and reputational risks posed to companies by their subsidiaries and business partners if adequate compliance systems are not in place; it also seeks to draw attention to the potential consequences for broader international security of illicit transfers. Continue reading The Toshiba-Kongsberg Case
Project Alpha researcher Daniel Salisbury published a piece with Susan Martin and David Takacs on The Conversation entitled ‘Chemical weapons and trade: preventing the next Syria’. Continue reading Chemical Weapons And Trade: Preventing The Next Syria
As a leading manufacturer of capacitance manometers, an item used to measure near-vacuum pressures in semiconductor, pharmaceutical or advanced coating processes, MKS products are perhaps the best example of a dual-use ‘chokepoint technology’ – an item without which some forms of gaseous uranium enrichment could falter or even be set back. Continue reading Preventing the Diversion of Sensitive Vacuum Measuring Equipment