TBML007 · TBML

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. When such goods move through trade, the risk turns on the commodity's classification, its end-use and its destination, not merely on the parties named. Trade in dual-use goods can be used to divert controlled items to prohibited end-uses under cover of ordinary commerce.

It is used to:

• Divert controlled goods to military or proliferation end-uses
• Move export-controlled technology through intermediaries
• Evade export licensing and end-use controls
• Support sanctioned or embargoed programmes
• Conceal the true end-user behind a civilian pretext

Risk narrative

A customer trades a commodity that is export-controlled — dual-use, with a military end-use or controlled-technology content. The trade documents describe a civilian transaction, but the commodity's classification and the destination indicate a controlled item bound for a sensitive end-user. Where the counterparty is a shell and the parties share ownership, the trade is a diversion channel rather than legitimate commerce.

Risk indicators

Risk

• Dual-Use Commodity
• Military End-Use
• Controlled Technology
• High Value Trade
• Related Party Trading
• Shell Company Structure

Investigation actions

1. Confirm the commodity classification, end-use and destination.
2. Screen the end-user against sanctions and entity lists.
3. Verify export licensing for the commodity and destination.
4. Resolve ownership; test for shared directors / owners and related-party trade.
5. Package evidence for investigator review where the score is High or above.

Use cases

• Trade Based Money Laundering (TBML)
• Export-Control / Dual-Use Diversion
• Proliferation Financing
• Sanctions Evasion
• Related Party Value Transfer

Related typologies

Curated from fc-04-tbml-analytics-toolkit/typologies/TBML007/TBML007_Dual_Use_Goods.md