Select Committee on International Development Written Evidence


Appendix 3:  Memorandum from the Foreign and Commonwealth Office

SECTION A: UPDATES

  The Committees would appreciate updates on the following topics. The aim should be to provide as far as possible information which can be published, but where important information can only be provided in confidence, the Committees would of course prefer to receive this rather than not.

1.  REVIEW OF THE EU ARMS EMBARGO ON CHINA—DEVELOPMENTS SINCE MAY 2004

  The review of the embargo instigated by the European Council continues. The EU's General Affairs and External Relations Council discussed this subject on 11 October, and will continue to take a keen interest in this subject.

2.  REVIEW OF THE EU CODE OF CONDUCT—DEVELOPMENTS SINCE MARCH 2004

  Significant progress has been made towards text for a new Code of Conduct, and the current draft is consistent with the UK objectives discussed previously with the Committees. In particular, there is strong support for making applications for brokering, intangible technology transfer, transit and transhipment licences subject to the Code's criteria.

3.  CRITERION EIGHT (SUSTAINABLE DEVELOPMENT)—DEVELOPMENTS SINCE MARCH 2004, INCLUDING PROGRESS TOWARDS A COMMON INTERPRETATION OF THE CRITERION AND PROGRESS IN THE WORK OF THE COARM WORKING PARTY ON THESE ISSUES

  As the Committees are aware, the UK is participating in an ad hoc group, which also comprises representatives from France, Germany, Netherlands and Sweden, which was mandated in February 2004 to produce a draft "Users" Guide' on Criterion 8 of the EU Code of Conduct.

  The aim of this guide is to promote greater consistency in Member States' assessments of licence applications against Criterion 8, without precluding the need for individual judgement. Further considerations are that the guide should be simple and practical to use, and should point users towards easily accessible data of use in making such assessments.

  This ad hoc group met for the third time on 29 September, and presented a draft document to the wider COARM meeting on 15 October. It is anticipated that a final version will be agreed at the subsequent COARM meeting in December.

4.  INTERNATIONAL EXPORT CONTROL REGIMES—DEVELOPMENTS SINCE MARCH 2004

Nuclear Suppliers Group

  The Nuclear Suppliers Group (NSG) Plenary was held in Gothenburg on 26-28 May. During the Plenary the Group accepted Lithuania, Estonia, Malta and China as Participating Governments. This recent expansion broadens the NSG membership to include all EU states, and all Nuclear Weapons States.

  The Plenary adopted a "catch all" mechanism into the NSG guidelines. This provision provides a national legal basis to control the export of nuclear related items that are not on the Control Lists. The Plenary adopted measures to modernise the NSG Information Exchange Meeting (IEM) and to improve the Group's outreach activities. The Plenary agreed to strengthen the relationship between the NSG and the IAEA.

  The next meeting of the NSG was an intersessional meeting, the Consultative Group, in Vienna from 20-22 October. The UK co-sponsored two proposals to amend the NSG guidelines. The first was to address recipient non-compliance with IAEA Safeguards obligations, and the second to introduce a set of criteria governing the supply of sensitive items and facilities to recipient states. A substantive discussion on these proposals is expected at the next meeting. Discussion on strengthening the relation ship between the NSG and the IAEA continued.

Zangger Committee

  The Zangger Committee met on 18-19 October. The Committee began discussion on the proposed revisions to the guidelines. Outreach activities were also discussed, and it was agreed to provide a report of the Committee's work to the UNSCR 1540 committee.

Missile Technology Control Regime

  The Missile Technology Control Regime (MTCR) last met in Paris 13-14 April at its intersessional meeting, the Re-enforced Point of Contact. The meeting discussed membership issues, and agreed to accept Bulgaria's application. It also discussed outreach activities. The MTCR most recently met in Seoul on 6-8 October for its annual Plenary. The Plenary admitted no new members to the regime. There were, however, fruitful discussions on outreach; transit, transhipment and brokering of MTCR-related items; and China's potential MTCR accession.

Australia Group

  The Australia Group (AG) met for its annual Plenary in Paris from 7-10 June. As part of the Group's ongoing work to keep its common control lists up to date and based on sound science, participants agreed to add five plant pathogens to the control lists. Discussion also focused on enhanced information sharing, and the Group agreed to consider the issue of brokering controls. Such controls could play a key role in curtailing the activities of intermediaries and front companies. The next Plenary meeting of the AG will be held in Australia in 2005.

Wassenaar Arrangement

  The WA held its first General Working Group meeting of the year in May. The meeting focused on taking forward conclusions from the Plenary in December. The UK continues to press for a denial notification system for military items (to match that for dual-use items) and a consultation mechanism for both types of controlled items.

  Outreach discussions have taken place with a number of target countries, including China, South Africa and Brazil. The UK co-organised an Outreach seminar for NGOs, think tanks, academic institutions, specialist media and representatives from non-WA member states on 19 October 2004, to increase awareness of the WA.

5.  PROGRESS ON APPLICATIONS OF NEW EU MEMBER STATES TO JOIN INTERNATIONAL EXPORT CONTROL REGIMES

Nuclear Suppliers Group

  Lithuania, Malta and Estonia—were accepted as Participating Governments during the NSG Plenary in May 2004. All EU Member States now participate in the NSG.

Zangger Committee

  Of the new EU Member States, Cyprus, Estonia, Latvia, Lithuania and Malta are currently not members. The UK fully supports the participation of all EU states in the Committee.

The Missile Technology Control Regime

  Cyprus, Estonia, Latvia, Lithuania, Malta, Slovenia and Slovakia are not currently in the Regime, but all have submitted applications. Discussion on outstanding applications will be held at the forthcoming MTCR Plenary in Seoul (4-8 October), the outcome of which is described above.

Australia Group

  All of the new EU Member States are members of the Australia Group. Estonian, Latvian, Lithuanian, Maltese, and Slovenian applications were accepted at the Plenary in June 2004.

Wassenaar Arrangement

  Slovenia, Malta, Lithuania, Latvia, Estonia and Cyprus are not currently members of the WA. The UK has participated in a number of intersessional meetings on membership and expects WA Participating States to make progress on this issue at the Plenary in December.

6.  OUTREACH—DEVELOPMENTS SINCE JANUARY 2004, AND COMMENT ON PURPOSE AND EFFECTIVENESS

  Since the beginning of 2004 the UK has conducted outreach visits to China, Hong Kong, Macao, the United Arab Emirates, Singapore, Serbia and Montenegro, Albania and Malaysia. We have also hosted visits from Israel and Ukraine, co-organised a conference for a number of EU Member States and (at the time) Acceding Countries in Slovakia, and participated in a number of multilateral outreach activities and conferences. In November we will be co-hosting with the US the 6th International Export Control Conference, in the DTI's headquarters building in London, at which over 150 delegates will be attending, from around 50 countries.

  The purpose of our outreach work is to assist other countries to improve their export controls, and to learn from their experiences. These countries range from those who already have a competent set-up, to those who need advice on establishing a robust export control system.

  Our outreach programme is conducted by officials from the FCO, MOD, HMCE and DTI. This cross-departmental approach has enabled us to provide advice across the range of relevant subjects. The US value our work and seek our participation in theirs. Outreach has already contributed significantly towards the UK's wider Counter Proliferation objectives. We have: helped to reinforce Hong Kong's export controls; assisted in the development of export control legislation in a number of Eastern European countries; promoted the EU Code of Conduct outside the current EU membership, such that several countries now ask our advice as to whether a proposed export should be permitted; established good export control links with South Africa, which have benefited to our wider Counter Proliferation relationship with that country; and encouraged Chinese export control reforms.

  Of course, UK technical assistance alone is not able to transform a poorly functioning export control system into an effective one. However, if the country in question has the political will to develop an effective system, and can devote the necessary resources to this activity, support and advice from countries such as the UK, who have experience of operating a rigorous export control regime, can be valuable.

7.  STRATEGIC EXPORT POLICY TOWARDS LIBYA—THE GOVERNMENT'S POLICY ON REVIEWING THE EU ARMS EMBARGO AND ON THE EXPORT OF STRATEGIC GOODS AND TECHNOLOGIES TO LIBYA

  The EU arms embargo on Libya was lifted at the 11 October GAERC (General Affairs and External Relations Council). The Government now considers all export licence applications to Libya on a case-by-case basis against the Consolidated Criteria.

8.  IMPLEMENTATION OF NEW CONTROLS UNDER THE EXPORT CONTROL ACT—DEVELOPMENTS SINCE MAY 2004, WITH COMMENT ON HOW THE GOVERNMENT HAS ADJUSTED IMPLEMENTATION OF THE CONTROLS IN THE LIGHT OF PRACTICAL EXPERIENCE, SUCH AS THE FARNBOROUGH AIR SHOW

Licensing under the new controls and against Regulatory, Impact Assessment (RIA) Estimates

  This table covers applications received/registrations from 1st Nov 2003 (ie the beginning of the six month implementation period) to end of August 2004.


Licence
RIA (forecast for 12 month period)
Actual Nos applications/registrations received to 31August 2004

OGL Registrations
  OGTCL
550
239
  Miltech OGEL
20-40
371
  "Individual Use" OGEL
170-200
239
  "Modcons" OGEL
Not estimated
128
Standard Individual Licence applications
  SITCL
900-1,500
81 (66 finalised at 31 August)
  SIEL (Miltech ITT)
800-900
323*
  WMD (new "end-use" controls)
very small
2
Open Individual Licence applications
  OITCL
Not estimated
68 (54 finalised at 31 August)
  OIEL (Miltech ITT)
Not estimated
129*
  WMD (new "end-use" controls)
Not estimated
15 (12 finalised at 31 August)


Processing times of licences introduced under the new controls

  This table covers the period 1 November 2003 to end August 2004.


Licence Group
Licence
% completed within 20 or 60 working day target as relevant

Standard Individual Licence applications
SITCL
SIEL (Miltech ITT)
WMD (new "end use" controls)
64% **
c79%***
0% (only 2 applications received however)
Open Individual Licence applications
OITCL
87%
OIEL (Miltech ITT)
c66%***
WMD (new "end-use" controls)
92%

*  These figures are based on licences issued for line items with an ML22 rating (for both physical and electronic transfers of technology)
**  This represents a decrease in performance caused by events unrelated to the introduction of the new controls and outside of HMG's control, that is, the UNSCR on Iraq and the need to delay processing until its finalisation.
***  These figures are (i) approximate as we do not differentiate between licences issued for physical and electronic transfers and (ii) based on licences issued for line items with an ML22 rating.


  The Export Control Organisation (ECO) has not received as many licence applications as predicted in the RIA revised after the public consultation (numbers are more in line with pre-consultation estimates). As the table above shows, the great majority of applications that have been received have been processed swiftly. The introduction of the new controls has not had an adverse impact on overall licensing performance, with performance against Government targets improving this year, to-date, on last year's performance figures. Also, we have not received negative feedback from licence applicants.

  Compliance visits have generally found that companies have prepared well for the new controls, and, importantly, that only a small number appear not to have sufficient awareness of them or satisfactory compliance procedures in place. This is now being addressed. Awareness visits to individual companies have confirmed this, showing successful training for and implementation of the new controls. A similar picture has emerged from feedback at regional awareness seminars where knowledge of the new control environment has been high. We intend to continue with our comprehensive awareness and wider outreach programme to ensure that this is sustained.

  The main industry requests for clarification have related to the WMD end-use controls and HMG has been working with those affected to explain in detail the practical effect of the new legislation, to iron out any uncertainties. The main residual concern raised by industry since the new controls completed their coming into force in May, was regarding the application of the WMD end-use control to those providing technical support to the UK MOD and troops on deployment. This has been addressed by the introduction of two new OGELs; the Military Goods: UK Forces deployed in non-embargoed destinations OGEL and the Military Goods: UK Forces deployed in Embargoed Destinations OGEL. The DTI guidance is being updated.

  Industry has previously expressed concerns about conflicting advice from DTI on the new controls. ECO strives to give exporters a consistent message, within the confines of a case-by-case approach to licence applications. We take seriously any suggestions of inconsistent generic advice. So far as all the instances brought to our attention have in fact related to slightly different questions/situations.

  The implementation of the Act was discussed at the October Export Control Advisory Committee (set up to create a structured dialogue between the Government and exporters), and at the October Defence Market Access Forum, and no substantive concerns were raised by industry.

  It is too soon to draw any firm conclusions but so far the new controls appear to be working as intended and at the same time do not appear to have caused any major difficulties for either industry or government. HMG will continue working with industry to address any further issues which arise, and will also continue to closely monitor the application of the controls.

Farnborough International Air Show

  In respect specifically of Farnborough, it would appear that, as a result of extensive awareness programmes and efficient licence processing, no major problems were encountered by the organisers, exhibitors or Government. We propose to adopt a similar approach to future trade fairs.

  ECO took steps to ensure that the organisers of and exhibitors at the Farnborough exhibition were aware of the UK's export control regime and its impact on them. HMG worked with the exhibition organisers, the Society of British Aerospace Companies (SBAC) in the run up to Farnborough on UK licensing requirements and made a special guidance note on the relevant UK export and trade controls available to the Farnborough organisers for dissemination to exhibitors. We also put this guidance on the website alongside the extensive guidance on the new controls. ECO provided awareness material for exhibitors on the UKTI stand at the exhibition and briefing on the new controls for UKTI and DTI staff who staffed the UKTI stand.

  The majority of licensable trade activities involving controlled goods that took place at Farnborough were covered by the Open General Trade Control Licence (OGTCL). Overseas exhibitors and visitors were eligible to register to use the OGTCL and in excess of 20 overseas companies exhibiting at Farnborough did so. Furthermore, overseas parent companies registered on behalf of themselves and in many cases several subsidiary companies. Allowing overseas companies to register to use the OGTCL negated the need for these companies to apply for individual licences and the resource implications attached to processing these licence applications. We intend to retain this approach for future trade fairs.

  As expected, there were some instances where exhibitors and visitors were planning to undertake licensable activities and were unable to use the OGTCL, for example for the promoting and marketing of long-range missiles and UAVs. The ECO ensured that all Farnborough related applications and all applications for Standard Individual Trade Control Licences (SITCLs) and Open Individual Trade Control Licences (14 in total) received before and during Farnborough were finalised in time.

  ECO established a dedicated helpline to provide advice to visitors to and exhibitors at Farnborough and we intend to follow a similar practice for future trade fairs.

9.  PROGRESS TOWARDS A COUNCIL REGULATION ON TRADE IN EQUIPMENT RELATED TO TORTURE AND CAPITAL PUNISHMENT

  Discussions at official level in Brussels continue on this subject. However, given that the European Commission revised proposal of 8 June 2004 introduced many new elements it is unlikely that the Regulation will be adopted during 2004.

10.  PROGRESS ON IMPLEMENTATION OF THE EU'S "ACTION PLAN FOR THE IMPLEMENTATION OF THE BASIC PRINCIPLES FOR AN EU STRATEGY AGAINST PROLIFERATION OF WEAPONS OF MASS DESTRUCTION" OF JUNE 2003

  An EU Strategy against the Proliferation of Weapons of Mass Destruction was agreed by the European Council in December 2003. The Strategy, and its associated Action Plan (agreed in June 2003) included both measures for immediate action, and measures for the coming months and the longer term.

  Progress in implementing the Strategy and Action Plan has been good in a number of areas. For example, the Peer Reviews of Member State' export control systems have been completed. The Task Force overseeing the Peer Review process is currently working on an action-oriented final report. The Report is likely to highlight best practices and identify areas where implementation of Dual-Use Items Regulation could be improved.

  A model non-proliferation clause for all mixed agreements with third countries was agreed in November 2003. This is an important example of the EU mainstreaming Counter Proliferation policies into its wider relations with third countries. This approach has been tested to the full in the protracted negotiation of the EU-Syria Association agreement.

  Other positive developments over the past year include agreeing a Common Position in favour of the universalisation of multilateral agreements; the continuation of the EU programme to assist the Former Soviet Union in disposing of WMD stocks; the promotion of a catch-all clause in various export control regimes, a series of outreach activities and EU endorsement of the Proliferation Security Initiative (PSI).

  The Strategy and its associated Action Plan were agreed as living documents. As such they must be responsive to changing priorities, such as, for example, the need to take action to encourage all states to fully implement the recently adopted United Nations Security Council Resolution 1540 and to back that up with the offer of technical assistance.

11.  COMMENT ON REPORT "US WEAPONS TECHNOLOGY AT RISK" OF THE US HOUSE OF REPRESENTATIVES COMMITTEE ON INTERNATIONAL RELATIONS OF 1 MAY 2004, AND SPECIFICALLY ON ITS FINDINGS RELATING TO THE BRITISH EXPORT CONTROL SYSTEM

  ****

12.  PROGRESS TOWARDS A BRITISH WAIVER FROM THE US ITAR REGULATIONS

  The terms of a United Kingdom waiver from the US International Traffic in Arms Regulations were agreed with the US Administration in May 2003. The waiver would apply to the export to the UK of certain unclassified defence items and technical data. New legislation as required by the US Arms Export Controls Act and the Security Assistance Act 2000 was proposed in the first Session of the 108th Congress, but was not enacted. The House International Relations Committee continues to have difficulties with the agreed waiver and published a report on the subject, as mentioned in the Committee's question 11. Enabling provisions were again deleted from the Defense Authorizations Bill in this Session. We shall discuss the US Administration the way forward on ITAR and licensing issues in the light of the Congressional language.

SECTION B: SPECIFIC LICENSING DECISIONS—2003, AND FIRST QUARTER 2004

  The Committees need to see sufficient information about the Government's licensing decisions to come to a reasonable understanding of why the Government has granted or refused a licence in any particular case. This should include an intelligible description of the goods, an indication of their value, the identity of the end user, and the stated end use of the goods. In the case of refusals and revocations, it should also include the reason for refusal or revocation.

  Where the Committees have requested information on a single licence application, it is open to the Government to provide information on other licence applications to the same country as well, if the Government would like to do so. A possible alternative to the past practice of laboriously compiling this information for the Committees might be to provide the Committees in confidence with the relevant case documentation, such as application forms and end-user undertakings.

13.  ALL REFUSALS AND REVOCATIONS DURING 2003

  ****

14.  INCORPORATION SIELS ISSUED DURING 2003 AND THE FIRST QUARTER OF 2004 FOR THE FOLLOWING DESTINATIONS (COUNTRIES WHICH HAVE NOT ALIGNED THEMSELVES WITH THE PRINCIPLES OF THE EU CODE OF CONDUCT).

  For incorporation SIELs, please also provide a description of the finished equipment in which the exports were intended for incorporation, and on the eventual end users of this finished equipment, where this is known, and on any end-use conditions attached to the export or use of the finished equipment.

  (a)  Australia,
  (b)  Bolivia,
  (c)  Brazil,
  (d)  Burma,
  (e)  China,
  (f)  Hong Kong,
  (g)  India,
  (h)  Indonesia,
  (i)  Iraq,
  (j)  Israel,
  (k)  Jordan,
  (1)  South Korea,
  (m)  Pakistan,
  (n)  Singapore,
  (o)  South Africa,
  (p)  Switzerland,
  (q)  Turkey,
  (r)  USA.

15.  SPECIFIC LICENCES ISSUED DURING 2003 AS FOLLOWS:

  (a)  Aruba: 10 submachine guns

  (b)  Australia: OIEL No 29. (This OIEL appears to allow the export in unlimited quantities of any equipment on the entire military list.)

  (c)  Fiji: equipment including 540 assault rifles and 101 general purpose machine guns

  (d)  Iraq: all licences

  (e)  Morocco: 200 submachine guns

  (f)  Turkey: OIEL No 30 for smoke hand grenades etc. OIEL No 32 for wide range of components

  (g)  Yemen: SIELs for small arms ammunition and weapons. sights

  (h)  Handcuffs: Barbados, Hong Kong, Malaysia and United Arab Emirates (and to Hong Kong in the first quarter of 2004). The Committees assume that these licences were for oversized handcuffs ostensibly for use as handcuffs on prisoners with large wrists. What steps did the Government take before granting these licences to ascertain whether the handcuffs might be used as leg-irons or shackles?

  (i)  Surface to air missiles: in 2003, Indonesia: OIEL No 9, Malaysia: OIEL No 69, South Africa SIELs; and in first quarter 2004, Oman: OIEL No 8, Singapore: OIEL No 7, Turkey: OIEL No 8.

  ****

16.  SPECIFIC LICENCES ISSUED DURING THE FIRST QUARTER OF 2004, AS FOLLOWS:

  (a)  Angola: Armoured all-wheel drive vehicles

  (b)  Guyana: 40 submachine guns

  (c)  India: OIEL No 8—"Goods as specified by the following entries of the EG(C)O 1994(as amended): ML4b, MLS, ML10 b,d,e,f,g,h, ML11, ML14, ML15, ML16, ML171, ML18, PL5017, ML21a & ML22".

  (d)  Israel: SIELs: Components for bombs; production equipment for optical target tracking equipment; weapon control systems. OIEL No 4: "components for surface to surface missile launching vehicles, components for armoured fighting vehicles"

  (e)  Maldives: an explanation for the refusal of a licence

  (f)  Qatar: 69 submachine guns

  (g)  USA: 20,000 semi-automatic pistols

  (h)  Uruguay: 763 semi-automatic pistols

  (i)  Venezuela: Weapon day and night sights

  (j)  OIELs granted for the export of body armour, components for body armour, bomb suits, military helmets, anti riot shields, ballistic shields, to countries including: Antigua and Barbuda, Bahamas, Barbados, Bermuda, Bulgaria, Sri Lanka, St Vincent, UAE.

  (j)  OIELs for wide-ranging equipment granted to Australia (No 13), Brazil (No 9), Canada (No 14), Japan (No 11), Poland (No 10), Singapore (No 10), Turkey (No 11), USA (No 27).

  ****

SECTION C: OTHER GOVERNMENT ACTIVITY

17.  ACTION BY CUSTOMS AND EXCISE SINCE JANUARY 2004

  The Committee would be grateful for details of any prosecutions relating to breaches of export controls: identifying court references, including the name of the judge and court, the identity of the defendant (if disclosable), the nature and details of the charges, the fine imposed, the type and quantity of goods involved, and the destination of the goods. The Committee would be grateful to know the number of cases since January 2004 that have been referred to specialist investigators, and the type and quantity of goods involved. The Committee would also appreciate an indication of the quantity of small arms and light weapons intended for export stopped by Customs and Excise since January 2004.

Prosecution case

  There have been no prosecutions in this period, but one case is expected to come before the courts in November.

Cases adopted by specialist investigators

  Five new cases have been adopted by specialist investigators during the period in question. Customs cannot comment on the detail of these cases which are either ongoing or in the court system. It their policy not to comment on cases where no formal charges have been brought, as to do so could prejudice ongoing enquiries or future criminal proceedings.

Small arms and light weapons

  Customs stopped a total of 81 firearms, 12 firearms parts, 286 rounds of ammunition 150 hand fired para illuminating rockets, 100 stun/training grenades and 700 thunderflashes.

18.  DETAILS OF PROMOTION ACTIVITIES BY MINISTERS FOR SPECIFIC DEFENCE EXPORTS SINCE OCTOBER 2003

Prime Minister

Czech Republic:

  The Prime Minister spoke to Vladimir Spidla, the then Czech Prime Minister, in the margins of the European Council on 13 December 2003, expressing support for the Anglo-Swedish aircraft Gripen.

FCO Ministers

Brazil:

  The Foreign Secretary expressed his support for the Gripen in his March 2004 meeting with the Brazilian Foreign Minister, Celso Amorim

Singapore:

  The Foreign Secretary's met with the Singapore Foreign Minister Jayakumar on 15 April 2004, and expressed HMG support for Typhoon (Eurofighter)

MOD Ministers

  Answer to follow.

19.  DETAILS OF SURPLUS MILITARY EQUIPMENT OFFERED FOR SALE BY THE GOVERNMENT SINCE JANUARY 2003, AND OF THE PURCHASERS OF THIS EQUIPMENT

  Military equipment that is surplus to the requirements of HM Forces may be offered for sale by the Government through the Ministry of Defence Disposal Services Agency (DSA). Information on the more significant export sales of military equipment is set out in the annual Report and Accounts of the DSA which is available on their website www.dsa.gov.uk. A central record of purchasers of military equipment is not available as a proportion of all sales are handled through firms on contract to the Agency.

  Military equipment sold to overseas purchasers requires a licence to export and this information is recorded against the buyer country in the quarterly report of Export Licensing Statistics. The second quarterly report will be displayed on the websites of the Department of Trade and Industry and Foreign and Commonwealth Office shortly.

  Equipment sold government-to-government, including surplus equipment, is listed against buyer country in a table of government-to-government transfers in the Annual Report on Strategic Export Controls. The next Annual Report will be published in mid-2005

20.  THE ANNUAL REPORT STATES THAT "IT IS NOT POSSIBLE TO BREAK DOWN EXPORTS COVERED BY AN OIEL AS TO IDENTIFY INCORPORATION CASES" (P 12). PLEASE EXPLAIN WHY THIS IS THE CASE

  There is currently no way to identify incorporation cases from our IT system without manually screening all the applications at the time of writing the Report. In addition, the nature of OIELs is such that they do not necessarily specify end-users in the permitted destinations; HMG nonetheless satisfies itself of the integrity of the exporter and assesses the full-range of risks associated with exporting the goods to the various destinations before issuing such licences. This includes incorporation where relevant.

September 2004





 
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