SRNL Supports Nonproliferation and Trade Through Training
Through the International Nonproliferation Export Control Program, staff at the Savannah River National Laboratory trained customs professionals in Italy on best practices in combating the export of items that have potential usage in weapons of mass destruction. Principal National Security Analyst James Davis and former INECP Principal Investigator Pam McKinsey led the three-day course titled Commodity Assessment Supporting Enforcement.
As a part of the National Nuclear Security Administration’s Office of Defense Nuclear Nonproliferation, INECP allows for training and other technical assistance needed to support export controls. SRNL, along with a few of DOE’s other national labs, are assigned areas of responsibility through INECP and have staff that serve as country leads to offer that training. SRNL provides country leadership for the Baltic and Balkan nations and Eastern Europe, while sharing the remainder of the European Union with Argonne National Laboratory.
“The INECP program has a wide range of curriculum and SMEs that can assist partner countries that are in the development stage of strategic trade controls (STCs) all the way through partner countries that have robust controls,” Davis said. “The [Italian Customs and Monopolies Agency] has established STCs, so our goal was to provide additional training on STC enforcement support.”
Principal National Security Analyst James Davis and former INECP Principal Investigator Pam McKinsey led a three-day course titled Commodity Assessment Supporting Enforcement in Italy at the Italian Customs and Monopolies Agency (ADM).
STCs are put into place to protect industry and national security while minimizing the risk that a foreign actor will use a dual-use export in a way that may hurt the Nation’s interest. A dual-use item is defined as any item that has “important uses in clean energy, modern science, advanced imaging techniques, sterilized equipment, and other applications,” but also has “legitimate civil and military applications” for weapons of mass destructions, according to the National Nuclear Security Administration.
Robust control language can keep certain items (even if they are not considered “dual-use”) from being exported to sanctioned entities. Any individual, company, or organization that has been identified as a national security concern can be labeled as a sanctioned entity, which subjects them to export restrictions and licensing requirements.
The course was designed to ensure front-line customs officers are submitting sufficient information to reach-back personnel when they suspect items of concern, and that the reach-back personnel can expedite the process of evaluating items and identifying the appropriate action to take on the request.
Davis explained the necessity of a thorough inquiry request because many times the agency doesn’t have time on its side. In some instances, they may only have a few hours to spare before an item is put on a ship and exported.
“It is a fine balance between prevention of proliferation, and facilitating trade, so this course helps [front-line officers] understand what they should be looking for and reinforces the process for reach-back personnel to identify commodities of concern and conduct a risk assessment on the transaction,” Davis said.
Once the inquiry request is sent by the front-line officer, the reach-back personnel must be able to determine if they have the authority to handle it. Sometimes they don’t have the authority to prevent ships from leaving a port and other times, they need to know when to direct the request to the proper licensing authority.
The reach-back personnel must then evaluate the commodity to determine if it is controlled by the countries STCs, and then evaluate the transaction (parties involved, declared values, quantities, etc.). Finally, the reach-back personnel would submit a response to the front-line officer with their recommended course of action on the item. All of this may need to occur at a relatively quick tempo, so proficiency is paramount.
Davis says that INECP courses are thoroughly vetted by the program leads before being released. Often, course instructors are selected based on their expertise. He has a degree in biochemistry and McKinsey was a microbiologist which comes in handy when reviewing controlled items because it can become extremely technical, Davis explained. Davis and McKinsey were able to assist attendees in evaluating items and deciphering the spec sheets that often come with them.
Ultimately, the primary goal of these courses is to aid in nonproliferation and improve international trade, Davis said.
“As a nation, the last thing you want is to export an item to a country of concern, a weapons program, or a non-state actor that’s going to use it for something else” he said. “If [countries] have strategic trade controls, it brings confidence to other countries … it provides that security and promotes international trade.”
As the team at SRNL continues to serve as subject matter experts for INECP courses, it is bringing them more opportunity for the future. Earlier this year, Davis and Lauren Jackson, Country lead for INECP and deputy program manager for the Export, Review, Compliance, and Interdiction program at the lab, visited with Moroccan government officials to conduct training and assist with putting STCs into place and determine how the country would conduct licensing. Members of the team have also recently developed training material for senior leadership in Vietnam and Thailand to just beginning to establish STC systems.