British exporters have been warned about the importance of conducting due diligence on their customers and suppliers following reports that British-made components have ended up in Russian weapons used in the war in Ukraine.
A “consistent pattern” of western parts being found in abandoned Russian kit has been reported by the Royal United Services Institute.
This has prompted a Whitehall investigation into how British components have come to be used in Russian weapon systems, the Telegraph reports.
Dual use
British parts found in Russian weapons include ‘dual use’ items – i.e. those which can be used for both military and civilian purposes.
The UK suspended all export licences for dual use items to Russia at the start of March, in response to the start of the war in Ukraine. An embargo on arms exports to Russia was introduced following the annexation of Crimea in 2014.
A spokesman for the Department for International Trade told the Guardian: “The UK has one of the most robust and transparent export-control regimes in the world. We take all credible allegations of breaches of export control seriously and we will take further action if appropriate.”
End user undertakings
Roger Arthey, chair of the IOE&IT Export Control Profession, told the IOE&IT Daily Update that the parts may not have been sold directly from the UK to Russia, but could have been re-exported from a third country.
He added, however, that UK control regulation requires British firms to do due diligence on the sales and onward sales of their goods to ensure they do not end up being used by prohibited users, including the Russian military.
“These items may well have originally been exported legally, but then re-exported contrary to the regulations or the conditions of the end-user undertakings, either deliberately or inadvertently,” he said.
Compliance responsibility
Richard Coker, a customs and trade consultant who delivers the IOE&IT’s export licensing controls training, agreed with Arthey and said that exporters must be aware of where their goods end up.
“In the training I deliver, I always try to educate participants that they need to be aware that their products could be subject to export compliance rules, no matter what the product is,” he said.
“The exporter must also be aware of who the end user or ultimate end user is, as the exporter has a responsibility for the use of their parts,” he added.
While acknowledging that it can be difficult for traders to have full visibility of their supply chains, Coker said traders need to “conduct as much due diligence as possible”.
