2026.03.28
Dual-use export licensing: the EU 2021/821 walkthrough
A practical map of when a licence is required, who issues it, and how long approvals actually take.
→ Read// PRACTICE AREA
Defence & Dual-Use
Export control, brokering licences, end-user certification, and EU regulatory compliance for defence-related trade.
// OVERVIEW
Defence and dual-use trade is regulated end-to-end: classification, licensing, end-user vetting, sanctions screening, and post-shipment reporting. Errors are not commercial — they are criminal. We act for manufacturers, brokers, and end-users on both sides of the EU export control framework.
We hold deep working knowledge of EU Regulation 2021/821 (Dual-Use), the Common Military List, BG Law on Export Control of Defence-Related Products, and the OFAC/EU/UK sanctions regimes. We coordinate with the Inter-Ministerial Council and the relevant licensing authorities for every transaction.
// WHAT WE DO
Specific work, named clearly.
01
Export control classification
ECCN, EU dual-use, and Common Military List classification with written opinions.
02
Brokering & transfer licences
Application and defence of licences before the BG Inter-Ministerial Council.
03
EU 2021/821 compliance
Internal procedures, training, and audit-ready compliance for dual-use exporters.
04
End-user certification
EUC drafting, verification, and post-shipment audit programmes.
05
Sanctions screening
EU, OFAC, UK HMT, and UN designated-party screening at counterparty and cargo level.
06
Internal Compliance Programmes
ICP design and implementation aligned with EU Recommendation 2019/1318.
07
Catch-all assessments
Article 4–10 catch-all reviews for non-listed items destined for sensitive end uses.
// HOW WE WORK
Diagnose. Scope. Deliver. Review.
01
Diagnose
We map the matter, surface the real risk, and define what success looks like before quoting.
02
Scope
Fixed fee or capped retainer with named deliverables, owners, and dates — in writing.
03
Deliver
Work product through the secure portal. Status visible at all times. No black box.
04
Review
Post-matter debrief, lessons captured, and renewal of the engagement only if it earns it.
// FAQ
Frequently asked.
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→ ReadHave a matter in Defence & Dual-Use?
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