Introduction - Open to Export

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Introduction
GREEN LIGHT EXPORTS CONSULTING
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What We Offer
If you are expanding your exports to emerging markets, we can help –
 to clarify - for your specific products, to specific markets - what is and
isn’t possible within embargoes and other constraints
 to avoid delay or denial of an F680 or export licence
 to factor in political and reputational risks
 In any of the emerging markets – Middle East, Africa, Asia, Latin America
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Source: SIPRI
Defence spend is contracting in mature
markets, expanding in emerging markets
Emerging markets = opportunities + risks
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‘Catch 22’



How can exporters of sensitive goods be sure their exports will not
breach sanctions, not be refused a licence, or not pose major
reputational risks?
You can only know if you will get a licence if you first get a
contract. How can you find out earlier? (NB F680s do not indicate
whether a licence will be granted)
If you export sensitive goods but do not need a licence, how do
you assess the risks?
We can help.
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Arms Embargoes, Sanctions, Asset
Freezes, Treaty Obligations
We can clarify what you can sell to whom, and what you
can’t. We also look ahead at the prospect of changes to
existing regimes.
Human Rights, Internal Repression
and International Humanitarian
Law
SOURCE: wikimedia.com
Neither HMG nor you want your goods associated
with repression. We advise on the risks, now and in
the future.
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Will your export
provoke or prolong
internal or regional
tensions or
conflicts?
If so, it will not be
permitted.
SOURCE: wordpress.com
We can advise.
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What is the risk of
your equipment or
technology being
used against UK or
allied forces?
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… or being diverted to an
undesirable end-user?
We can help navigate the UK trade
licensing process
Applicant
Applicant
(application)
(RFIs)
Licence
Reception
Licensing
Unit
Enforcement
Unit
Technical
Assessment
Unit
Applicant
(RFIs)
Licensing
Unit
Other Government Departments (OGD) Advisors
DECC
DfID
CWC
NSG
CHSD
Posts
GCHQ
FCO
CPD
AEPT
Posts
CESG
OIEL
REJECTE
D
Apply for
SIELs
Licence
Issued
Applicant
ECO
Compliance
Unit Visit
Report to
ECO via
Spire
MOD
OIEL
Suspended
(exports)
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… and the MOD F680 process
FCO
AEPD
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ELT, IOD, SecPol
HRDGG, Posts
Capability Protection
EXPORTER
MOD
ACP
Def Sy (Sc & Tech)
Defence Intelligence Staff
DFID
… and avoid delays with applications
Query
Cause(s)
EUU
EUU and ELA contain contradictory information. The EUU is out of date,
unsigned or is signed by multiple parties. It’s not possible to determine
who signed the EUU (no letter head). EUU contains an electronic
signature.
Tech Specs.
The technical information does not include the relevant assessment
parameters from the related control entry.
Goods Descriptions
The goods description should describe the goods, not their design
origin or purpose.
Third Parties
There are third parties / ultimate end users listed on the EUU that are
not listed on the application.
Incorporation
Knowing when your consignee is your end user because they are
incorporating or integrating your goods.
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We look in detail at
equipment/end-user combinations
Nigeria: CT/Surveillance Equipment

All applications to export equipment that could be linked to the arrest and subsequent mistreatment
of suspects, such as mobile phone tracking equipment, will be subject to close scrutiny. HMG has not
recently authorised the permanent export of any lethal equipment to the Nigerian Armed Forces or
Police.

There are specific concerns surrounding the use of surveillance equipment, such as that used for
mobile phone interception, by the Nigerian authorities including the Department of State Services
(the State Security Services)

HMG will look closely at the potential proximity of such equipment to allegations of mistreatment in
detention centres and whether that equipment is sufficiently linked to the mistreatment of those
incarcerated if it is used during arrest and detention procedures

approval of equipment for direct use in CT operations in Nigeria would be highly unlikely under the
present circumstances
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1 - Embargoes/Treaties
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2 – Internal repression
3 – Internal tensions or conflict
4 – Regional instability
5 – UK National security
6 – Behaviour of buyer country
7 - Risk of diversion
8 – Economic capacity of buyer…
TOTAL
0
50
100
150
200
We analyse the reasons for past export
licence refusals (2013 figures)
250
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We cover all emerging markets
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