SAN007 · Sanctions

Dual Use Goods

Dual-use goods are items with a legitimate civilian use that can also serve a military or proliferation purpose — electronics, precision instruments, controlled technology. Sanctions and export controls turn on the commodity's classification, its end-use and its destination, not merely on the parties named.

The finding is a commodity-control finding: whether the item is export-controlled, whether there is a military end-use or controlled technology, and where the end-user sits — weighted against the end-user's own risk and any ownership link to a designated party.

Risk indicators

Commodity-Control

• Dual-use / export-controlled classification
• Military end-use
• Controlled technology transfer

Jurisdiction

• Sanctioned / embargoed destination
• High-risk destination

Counterparty (End-User)

• End-user sanctions exposure or adverse media

Ownership

• End-user owned by a designated party
• Opaque end-user ownership

Investigation actions

1. Resolve the consignment, its end-user and owner.
2. Classify the commodity (dual-use, military end-use, controlled technology).
3. Score jurisdiction exposure for the destination.
4. Score end-user (counterparty) exposure and any ownership link to a designated party.
5. Aggregate; escalate at or above the threshold.

Detection logic

1. Resolve the consignment, its end-user and owner. 2. Classify the commodity (dual-use, military end-use, controlled technology). 3. Score jurisdiction exposure for the destination. 4. Score end-user (counterparty) exposure and any ownership link to a designated party. 5. Aggregate; escalate at or above the threshold.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN007_Dual_Use_Goods.md