Trade restrictions and dual-use goods

Some sanctions regimes go beyond financial restrictions and impose controls on the movement of goods, technology and services.

Particular caution should be exercised where matters involve:

Dual-use goods are items that may have both civilian and military applications.

Lawyers should not assume that a matter is low risk simply because no sanctioned person has been identified. Certain transactions may be prohibited because of the goods, technology or services involved.

Where trade restrictions may be relevant, guidance should be sought before proceeding. You must not determine independently that a sanctions licence, exception, exemption or other authorisation is available. Any proposed reliance on one must be referred to the MLRO and supported by appropriate specialist advice where required.

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