UK Publishes Guidance on Exporting Dual-Use Technology
The United Kingdom's Department for International Trade released a business guidance to exporters of military or dual-use technology on the definitions and scope of the technology in question along with export control concerns. The March 18 publication answers a litany of questions including to whom the export controls apply, the basis of export controls on technology, the definition and scope of the relevant technology, the scope of technology transfer in question, export controls exemptions and the relevant export licenses. The guidance opened broadly, laying out the types of technology covered under the export control regime. Generally, the pertinent technology includes blueprints, plans, diagrams, models, formulae, tables, engineering designs and manuals relating to WMD, certain arms embargoes and unauthorized military exports.
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If an exporter is looking to transfer technology covered by the export control regime to a foreign entity, the guidance points to three Open General Export License that are of particular interest. The OGELs for overseas access to software and technology for military goods (individual use), technology for military goods and technology for dual-use items are the three primary export licenses applicable to dual-use tech transfer. If these three are not appropriate for a given piece of technology, then an exporter must apply for a standard individual export license or an open individual export license, the guidance said.