The Export of Listed Products
Under the Law of Georgia on International Economic Sanctions, the export of products determined by the control lists is carried out on the basis of an export permit issued in accordance with Georgian legislation. The first legal step of any sanctions compliance policy is therefore precisely the classification of the product within the relevant category and the obtaining of the appropriate permit. An operation carried out without a permit constitutes a violation of the law and entails corresponding liability. Planning an export operation therefore requires a consistent sequence: the product's relation to the control list, the corresponding authorized organ and the type of permit sought, followed by careful documentation of each stage. Correct classification saves time and shields the company from subsequent sanctions, while international partners often demand proof of compliance before contracting.
Authorized Organs and Types of Permits
Permits for military products are issued by the Ministry of Defense of Georgia, the authorized organ for military products determined by the control list. It issues permits for export, import, transit, brokering services and technical assistance. For dual-use products the authorized organ is the Revenue Service, which likewise issues all five types of permits. Permits for dual-use products are issued on the recommendation of the standing military-technical commission of the Ministry of Defense, where the product is marked in the control list with one or two asterisks. This distribution means that one and the same company may have to work with different organs for different products.
Refusal, Suspension and Annulment of Permits
The organ issuing the permit may refuse to issue it, suspend an issued permit or annul it — including by declaring it void or invalid, or lost in force. This is possible in the cases provided for by the Law on Licenses and Permits, on a basis defined by the relevant normative act, and also on grounds of state interest or where an embargo or state sanction has been imposed against a specific country. The Revenue Service is authorized to suspend the export, import or transit of products where new circumstances have arisen or been discovered that require study by the competent organ and that would not have been taken into account when the permit was issued; in such a case the file is sent to the corresponding competent organ for reconsideration, and the decision may change also on grounds of state interest.
International Sanctions and Control
Georgia's participation in international economic sanctions against one or more countries is determined by Georgian legislation or is based on a decision of the United Nations or another international organization. Georgia may also impose such sanctions unilaterally, and where sanctions are imposed, the procedure for compensating damage is determined by legislation. The working group of the governmental commission working on compliance with the UN Security Council resolutions is authorized to impose prohibitions as well, including on export, import and transit; these prohibitions are mandatory for the administrative organs that receive such an assignment. In terms of control, the permit holder is obliged to keep a register of licensed activity, which is stored for 6 years; the period is counted from the end of the calendar year in which the permit expires, and primary accounting documents must also be kept for no less than this period. A durable compliance system differs from a one-off permit: it includes screening each transaction against the control lists, communication with the authorized organ, staff instructions and the 6-year storage of the register and accounting documents — elements that an audit requests first.
Frequently Asked Questions
Who issues permits for military and dual-use products?
For military products — the Ministry of Defense; for dual-use products — the Revenue Service. Both issue all five types: export, import, transit, brokering and technical assistance permits.
When may a permit be annulled?
In the cases provided by the Law on Licenses and Permits, on a basis defined by normative act, or upon the imposition of an embargo or state sanction against a specific country.
What happens when new circumstances are discovered?
The Revenue Service suspends the export, import or transit and sends the file to the competent organ for reconsideration.
How is participation in sanctions determined?
By Georgian legislation or on the basis of a decision of the United Nations or another international organization; unilateral sanctions are also permitted, and the compensation procedure is determined by legislation.
For how long must the licensed-activity register be kept?
For 6 years, counted from the end of the calendar year in which the permit expires.
How We Help on Legal.ge
If your company plans to deal in products determined by the control lists, on domestic or international markets, write to us through the contact form on this site. The legal specialists of Legal.ge will assess the category of your products, help you prepare the permit application and build internal compliance procedures. A sanctions-related mistake is costly — contact us today. We will assess your export portfolio as a whole and mark the items where the risk is highest, fixing every classification decision in writing.