How to detect dual-use items?

This concept, known as dual-use goods, sits at the intersection of technology, ethics, and global security, shaping industries and policies in ways that affect us all.


Let’s explore how compliance professionals can detect dual-use goods.

What are dual-use goods?

Dual-use goods are items that serve both civilian and military functions, making them subject to strict regulations due to their potential security risks. These goods can range from software and technology to physical products that, while initially intended for non-military use, can be repurposed for military applications or even acts of terrorism.
Technology, in the context of dual-use regulations, refers to the information necessary for the development, production, or use of controlled goods. This encompasses a wide range of materials, from blueprints and engineering designs to manuals and digital files stored on various media.

Companies dealing with these items must comply with stringent legal frameworks to ensure that their products do not contribute to global security threats.

What are examples of dual-use items?

You might be surprised at what items can be considered dual use. Below are a few examples:

Product	Civilian Use	Military Use
Triethanolamine	Chemical component used in shampoo.	Can also be used to create chemical weapons.
Carbon fiber	Used in the creation of tennis rackets.	Also used in the creation of missile fuselage.
Lyophilizer	Machine used for creating instant coffee.	Can also create biological weapons.
Ammonium nitrate	Used as a fertilizer in agriculture.	Can also be a key component in explosives.
Aluminum powder	Used in paints, fireworks, and electronics.	Can be used in solid rocket fuel for missiles.
Thermal imaging cameras	Used in firefighting, medical diagnostics, and search & rescue.	Essential for night vision in military operations.

How to identify dual-use goods?

Checking if your company or financial institution might be dealing with dual-use goods can be challenging, as it requires careful analysis of both the product's civilian applications and its potential military uses.

There are several websites which can help you with this search. Below is a list with a link:

• 1

  The Wassenaar Arrangement - the official website of the international export control regime that aims to promote transparency and responsibility in the trade of dual-use goods and military technologies offers a downloadable PDF with the list of dual-use items.

• 2

  European Union – the EU’s website on exporting dual-use goods offers various resources, including a PDF list of dual-use items.

• 3

  U.K. Department of International Trade – their Goods Checker tool allows you to input the name of the suspected dual-use item that you are searching for and see if it appears on any lists.

• 4

  U.S. Bureau of Industry and Security – allows you to search for specific items to see if they are controlled under the Export Administration Regulations (EAR) and classified as dual-use.

What to do when a dual-use item is identified?

Once compliance professionals identify a dual-use item being traded by a customer, the first step is to conduct a thorough risk assessment.

Compliance teams must evaluate the specific item, its intended end-use, and the destination country to determine whether the transaction violates any export control laws or sanctions. This involves cross-referencing the item against relevant control lists, such as the Wassenaar Arrangement, EU Dual-Use Regulation, or the U.S. Commerce Control List (CCL), and assessing the customer's profile for any red flags, such as ties to restricted entities or high-risk jurisdictions.


In cases where the item requires an export license, the compliance team must ensure that the necessary authorization is obtained from the relevant regulatory authority before proceeding.

Exporting dual-use goods requires careful adherence to licensing processes. Exporters must first determine whether a license is needed by reviewing the item, its destination, and the end-user. If a license is required, they must apply for and obtain it before shipping the goods. This process ensures compliance with international and national regulations. Financial institutions, insurance companies, and other parties involved in cross-border trade also have a responsibility to verify that transactions involving dual-use goods are lawful and compliant.

What are the regulations surrounding dual-use goods?

In Europe, the EU controls the export, transit, brokering, and technical assistance of dual-use items under Regulation (EU) 2021/821. This regulation aligns with international obligations, such as UN Security Council Resolution 1540 and treaties like the Nuclear Non-Proliferation Treaty, the Chemical Weapons Convention, and the Biological Weapons Convention.

The EU also offers various types of export authorizations, including:

• EU General Export Authorisations (EUGEAs) under Regulation (EU) 2021/821 allow the export of dual-use items to specific destinations under certain conditions. These authorizations cover exports to countries like the U.S., U.K., Canada, and Japan, as well as specific cases such as repair and replacement, temporary exports for exhibitions, telecommunications, chemicals, intra-group technology transfers, and encryption.

• National General Export Authorisations (NGEAs) may also be issued by EU Member States, provided they align with existing EUGEAs and exclude items listed in Annex IIg of the Regulation.

• Global licenses issued by competent authorities to an exporter and can cover multiple countries of destination, goods, or end users.

• Individual licenses issued by competent authorities to an exporter and can cover the export of one or more dual-use goods to a single end user in a third country.

On January 24, 2024, the Commission released a White Paper on Export Controls, proposing ways to strengthen EU export controls amid rising geopolitical tensions to enhance international security and protect the EU's strategic interests. In January 2025, the EU released a report with the purpose to modernised EU Export Control Regulation.

Different regions have established their own frameworks for regulating dual-use goods:

• United Kingdom: The Financial Conduct Authority (FCA) sets regulatory expectations for dual-use goods, while the EU provides guidance to help identify and manage their impact.

• United States: While the U.S. does not explicitly require financial services firms to identify dual-use goods in trade finance transactions, there is growing pressure for them to do so, given the country’s aggressive enforcement of export control violations.

There are also several voluntary multilateral export control regimes that have been established to harmonize export controls and enhance international cooperation. These include:

Dual-use goods: contributing to global peace

Financial institutions, insurance providers, and other entities involved in cross-border transactions of dual-use goods play a crucial role in ensuring compliance with international trade laws and regulations.

The trade of dual-use goods requires rigorous compliance with export control regulations to prevent misuse and uphold international security.

By understanding the licensing process, adhering to regional and multilateral frameworks, and staying informed about evolving regulations, businesses and compliance professionals can contribute to global peace and security while avoiding legal and reputational risks.