Manufacturers and brokers of military matériel or other embargoed goods

  • Ensure that no party associated with the acquisition of material is already designated under UN sanctions;
  • In a case where any party associated with the acquisition of goods is designated under any sanctions regime (other than a UN regime), clarify whether UN sanctions could be justified or their imposition might be reasonably expected;
  • With first-time clients, suppliers, and subcontractors, verify identification documents, conduct background checks using both government and private sector data. Emphasize the need for identification verification for all partners, but particularly for procurement agents and all other individuals, companies and entities representing buyers, suppliers or subcontractors or those referring and introducing them, conducting negotiations on their behalf, or providing specialized services such as technical procurement advice, legal counseling, as well as those providing financing and transportation resources;
  • Verify that end-use and end-user documentation is authentic, valid for the time period under consideration and for the items proposed for procurement;
  • For any buyer, conduct due diligence, for example:
  • ensure that items proposed for acquisition match or are compatible with existing arsenals;
  • if inconsistent with existing stocks, vet the rationale behind the decision to change weapons systems;
  • ensure that the ordering state has adequate budget allocations for proposed acquisition;
  • in cases where other unilateral or regional restrictions exist, check that they are not indicative of a general pattern of assisting third parties in violating UN sanctions.
  • In cases of proposed procurement of items, components, technologies or information restricted under a WMD embargo, verify familiarity of buyer with the products’ properties.
  • Require plausible and verifiable explanations in cases where purchaser refuses standard procedures, such as verification of technical specifications, transport and financing procedures, or declines post-sales services, such as installation, maintenance, or training, or in cases where:
  • Inquiries lack specific delivery dates;
  • Inconsistencies exist between technical properties of the items of interest and the technical capacities of the country of destination;
  • Acquired items are identified on shipping documents as sent for “evaluation”, “diagnosis”, or “repair”, contradicting document of sale and concealing true ownership;
  • Method and route of delivery are logical and consistent with the stated purpose of the procurement and end-use certification.