08.2020_MEU_WP_v5
 
Kharon’s white paper The New Military End Use and End User Regulations: A Guide for Identifying Risk delves into the US Department of Commerce Bureau of Industry and Security’s (BIS) expanded license requirements on exports, re-exports, and transfers of items intended for military end use or military end users in China, Russia, or Venezuela.
 
The new rule broadens the list of items covered by military end use licensing requirements and expands the definition of “military end use” to cover broader categories of activity. The rule also establishes new restrictions on exports to military end users in China. Requirements for end use and end users have been in effect since 2014 for both Russia and Venezuela, but the restrictions on China, in place since 2007, only covered end use.
 
In this paper we bring into focus the importance of going beyond the sanctions list for screening and due diligence in order to identify exposure to customers that present material risk considerations for the control framework. In particular we address the following risk, data and relationship types that can be surfaced within the first few days following each new designation:   
 
+ Expansion of the definition of military end use
+ Military end user restrictions
+ Procurement agents and distribution partners 
+ Understanding ownership chains and activities that support military end uses
 
 
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ABOUT KHARON 
 
Kharon is a leading provider of research and data analytics, focused on global security threats and other controversies that impact global commerce and finance. Kharon's clients include first tier international financial institutions, global corporates, public sector entities and professional services firms. Kharon is headed by former senior intelligence officials from the U.S. Department of the Treasury, and experienced professionals in software development and data science.
 
If you would like to discuss how Kharon can support your business response to the new regulations or any of the information in this white paper, please contact info@kharon.com for more details.