Efficient Processing of Government to Government Assurances (GTGA)
Efficient processing of Government to Government Assurances (GTGAs)
A fundamental part of the international nuclear non-proliferation infrastructure is the requirement for Government to Government Assurances (GTGAs) to be given before the export of certain types of sensitive nuclear material, equipment and technology is authorised. The principle behind this requirement is that notifications of particularly sensitive exports for nuclear end-use are conveyed directly between Governments so that the legitimacy of the proposed export and End-Use can be verified. All items included on the NSG Trigger List are to be subject to an Assurance.
More information regarding the requirements of this process can be found in the Guidelines for nuclear Transfers(INFCIRC/254, Part 1), and also on the page on the NSG website which introduces the Guidelines (http://www.nuclearsuppliersgroup.org/en/guidelines).
There are several parts to the GTGA process – in addition to the exchange of documents between Governments, there is also the verification step mentioned above. The recipient company/entity has a vital role to play in the effective and prompt processing of GTGA requests.
If any Governments involved in the GTGA process who are not Participating Governments within the NSG would like to discuss GTGA requests or provide points of contacts and relevant details to improve the processing of GTGAs, please get in touch with the NSG.
The role of companies in the GTGA process
Companies/entities involved in the export have a vital role to play in the efficient processing of GTGA requests. They can ensure the part they play in the GTGA process is as streamlined as possible by:
- Understanding what information they will be asked to provide, why it is necessary, what is required and to appreciate that providing it as quickly as possible is vital for all concerned
- The exporting company ensuring that their customer (the recipient company) is aware that the items intended for export is subject to certain NSG requirements
- The exporting company ensuring that the contact details of the responsible person(s) in the recipient company are included in licence applications
- The recipient company understanding that they will need to provide information to their Government, and that the person(s) within the recipient company/entity who can do this must have sufficient seniority and authority to provide the requested information on behalf of their company/entity.
In addition, exporting companies should consider export licence applications carefully. This includes providing adequate goods descriptions and accurate consignee/end user details. The exporting company should work with their export licensing authority to ensure that any licence applications they submit are appropriate and meet their requirements.
All companies should have an appreciation of the GTGA process so that properly targeted applications are made. For example, the more end users that are included on a licence application, the more Government-Industry interaction that will be needed before the overall GTGA can be provided to the requesting Government (as the relevant information from all the end users listed on a licence will need to be provided before a GTGA can be issued).
Note: These are also suggested actions which can be implemented if it is decided that they would or could be useful. It is up to those involved in the GTGA process to decide how much information they wish to share, or how they might want to take forward any of the suggested actions. There is no obligation or expectation placed on any party as a result of these suggestions.