UNICORN PRIVATE Sanctions risks for manufacturers and dual use exporters: what to check
In short
Manufacturers that export goods with civil and military uses need an export licence for many destinations.
The main risks are listed buyers, goods diverted through third countries and end users hidden behind intermediaries.
Check each buyer, owner and end user against the sanctions lists and classify your goods before you export.
Typical sanctions risks in this industry
- Selling to a buyer, distributor or end user who is on a sanctions or export control list.
- Exporting dual use goods without the required licence, because the goods were not classified correctly.
- Goods diverted to a sanctioned country through intermediaries in third countries.
- Buyers owned or controlled by listed persons, which are not visible from the company name alone.
- Spare parts and services for machines already delivered to parties that were later listed.
Recommended checks
- Classify every product against the EU dual use list and, when relevant, the US Export Administration Regulations.
- Screen buyers, owners, banks and end users against the sanctions lists before the order and every day after.
- Ask for end user statements and check that quantities and uses are plausible.
- Watch for warning signs, such as unusual routes, cash payments or refusal to state the end use.
- Keep records of classifications, licences and checks.
Official sources
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Frequently asked questions
What are dual use goods?
They are goods, software and technology that can be used for both civil and military purposes. In the EU they are listed in Regulation (EU) 2021/821.
Is it enough to check the buyer?
No. Owners, banks, intermediaries and end users can be listed too, and goods can be diverted through third countries.
Do US rules matter for a European manufacturer?
They can, for example when the products contain items of US origin or when payments are made in US dollars.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.