Is a specific license required when sending goods inter-company to embargoed countries?

Question

In reference to embargoed countries, we on occasion may be asked to deliver goods intercompany – this may not always be the end user- do i need a specific license and what is the best way of managing end users as this may not always be declared?

(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)

Answer

Licences are required even for intercompany shipments, but if your company is located in an embargoed country then it’s unlikely you’ll get a licence.

Answer

Thank you for your question

Although many embargos are different (and may be brought into force by different entities), the ECO website carries the following explanation:
"An arms embargo is a prohibition or sanction against the export of weaponry and dual-use items – goods which have both a civil and military use. An arms embargo might be imposed via various routes such as by the UN, EU or OSCE and where the UK has imposed regulations as a result."
(https://www.gov.uk/guidance/current-arms-embargoes-and-other-restrictions)
The Export Control Order of 2008 carries the following definition:
"“embargoed destination” means a country listed in Part 1 or 2 of Schedule 4;" [of the order]

We would need further information from you to provide advice on your question ie what are the goods; where are the goods being exported from; are they being sent for stock purposes etc.

See this guide https://www.gov.uk/guidance/end-user-and-consignee-undertakings-for-siels-and-oiels which explains the importance of knowing who the end user is; and outlines the completion process for the End User Undertaking.

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