Ensure risk-based proportionality in export licences

The duration of export licences containing nuclear-related items should be increased to five years as standard, and consideration given to increasing this to ten years. There should be an adoption of a risk-based, proportionate approach to the level of information required as part of any application and record-keeping. This could mirror the risk-based approach adopted under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. The overall aim of this should be to operate on a more generic basis, based on the actual risks involved.

Applications for exports of the same items to any entity which has previously been granted an export licence should be decided within 28 days. If amendments to the Export Control Order 2008 are needed to give effect to these recommendations, that should be considered at the earliest opportunity.

The ONR and EA should be granted ten year open licences which cover their regulatory activities in relation to its functions in collaborating with regulators.

The Export Controls Joint Unit (ECJU) should establish a dedicated point of contact for nuclear companies and government teams involved in strategic nuclear export licensing. This resource should have the capability to engage meaningfully with nuclear specific matters in order to efficiently process licences in this area.