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Proliferation Financing

Dual-Use Export & Procurement Diversion

Procurement of dual-use or export-controlled goods routed through intermediaries and transhipment hubs to evade export controls and proliferation sanctions. Front buyers, mismatched end-users, and circuitous shipping routes disguise the true destination of sensitive items.

Firm typesBank / Credit InstitutionE-Money Institution (EMI)Payment Institution (PI)Money Service Business (MSB)
ProductsTrade FinanceCross-Border PaymentsFX Transfers
CustomersCorporatesSMEsAgents & Intermediaries
Key terms:

What it is

Procurement of dual-use or export-controlled goods routed through intermediaries and transhipment hubs to evade export controls and proliferation sanctions. Front buyers, mismatched end-users, and circuitous shipping routes disguise the true destination of sensitive items.

Control objective

Detect financing of dual-use and controlled-goods procurement routed via intermediaries and transhipment hubs to evade export controls and proliferation-financing sanctions.

Data required

  • Goods description and dual-use or controlled-goods classification
  • End-user and end-use declarations
  • Shipping route, transhipment points, and consignee details
  • Counterparty network and intermediary relationships
  • Originating and beneficiary jurisdictions versus stated destination
  • Trade documentation (invoices, bills of lading, licences)
  • Sanctions and proliferation-list screening across all parties
  • Price and quantity reasonableness versus declared end-use