UK exporter fined for unlicensed brokering
The United Kingdom’s Export Control Joint Unit has announced that Her Majesty’s Revenue & Customs (‘HMRC’) ‘has recently issued a compound penalty of £10,234.26 to a UK exporter/trader.’
The penalty, it says, was in relation to unlicensed trading of body armour, and while the goods were not exported from the UK, ‘the transaction involved a UK national.’
UK government guidance states that it regards ‘brokering services’ as constituting ‘the selling or buying of dual-use items or the deal, negotiation or transaction for purchasing or supplying dual-use items from a third country to any other third country.
‘In practice, brokering could include the following activities – this list is not exhaustive:
- arranging supply from overseas factories/warehouses
- arranging intra-company transfers
- drop shipping
- acting as a “project manager” for a project in one third country who sources supplies for that project in other third countries
‘Brokering, under the regulation, does not include ancillary services (defined as “transportation, financial services, insurance or re-insurance or general advertising or promotion”).’
