export-controls 24 January 2019

Wassenaar proposes new questions for companies’ due diligence

The Wassenaar Arrangement has updated its control lists (December 2018), and at the same time updated its list of indicative questions for companies to use ‘in any export situation’.

It says that ‘being vigilant for signs of suspicious enquiries or orders is vital for countering the risks of the proliferation of sensitive goods and technologies and destabilising accumulations of conventional weapons.’

The 35 questions relate to:

  • The product a company is selling
  • End-user and end use
  • Shipment, and
  • Finance and contract conditions

It says: ‘[C]orresponding answers to any of the questions…should not be considered as the basis for an automatic rejection of an export. The intention of the questions is rather to flag the need for greater scrutiny while examining exports.’

See:
https://www.wassenaar.org/app/uploads/2018/12/Advisory-Questions-for-Industry-Amended.pdf