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.