08-06-2021 | | By Robin Mitchell
Recently, a resident of Nevada State was arrested for illegally shipping restricted electronic devices to Iran via intermediaries in Honk Kong. Why are some components restricted for export, what examples exist for device restrictions, and how can engineers determine if they are shipping something restricted?
When it comes to shipping electronic components, most engineers and consumers will almost never see or hear of an item they cannot ship. One exception to this would be the sending of Lithium-Ion batteries; these are generally not allowed to be sent in the post due to their fire risk.
However, some electronic components cannot be sent outside of countries or sent to specific countries without a license, or cannot be sent at all. This has nothing to do with the safety of transport or safety of handling but instead due to national security.
A country may choose to limit the export of certain technologies as they could provide foreign nations with some advantage whether it be an economic or military advantage. For example, the recent tension between the US and China has seen the US impose restrictions on allowing China to license the ARM core architecture.
As a result of such restrictions, extra care should be taken when sending electronics around the world. What may seem like a mundane piece of hardware could potentially be a national security risk. However, while it may be easy to accidentally send a piece of restricted hardware, some actively try to get around these restrictions.
Recently, a resident of Nevada State (United States of America), had been found to be exporting sensitive electronics to Iran which currently has a large number of sanctions against it. Tina Chen was found to have purchased goods from US companies using her business which were then shipped to Iran using an intermediary in Honk Kong.
Devices tent include Photomultipliers, bandpass filters, and wireless transceivers , all highly associated with military technology. Tina Chen said that the shipment was due for Zanjen University. However, it is well known that governments such as those in China and Iran often interfere or have outright control over companies both private and public. The trial of Tina Chen is scheduled for July 26th, and is now up to her legal team to convince the United States government that the shipment was not for military use.
As stated previously, some components are export-controlled to provide an economic advantage over other companies, but most are arguably to provide a military advantage. This can be clearly seen when looking into what systems are banned, and here we will look at a few examples.
Infrared cameras are export-controlled, and only those that have a refresh rate of 9fps or lower can be exported freely. You may wonder why IR cameras are restricted when visible cameras are widely available, but the truth lies in their ability to see heat, see where we are going with this?
IR cameras with refresh rates over 9fps can be implemented into heat-seeking missiles whose velocity is supersonic. While most nations possess such missiles, it’s best if such technology can be kept out of reach of those who have a particular enthusiasm for model rockets and things that explode. Of course, it is extremely unlikely for a citizen of a nation to create such a rocket (even less likely to use it), but there are many foreign non-government forces who would be particularly interested to own such missiles.
Photomultipliers (like the ones sent by Tina Chen), are export-controlled depending on their capabilities, and this most likely stems from their ability to create night-vision systems. The ability to see in the dark gives any military force a major competitive edge, and while most nations have access to such hardware, it is best if this can be limited to nations and not rouge forces.
Oddly enough, band-pass filters are another device that sometimes makes its way onto export-controlled lists. According to the Bureau of Industry and Security, band-pass filters with a centre bandwidth of more than 0.5%ands filters that are electronically tuneable having more than 5 tunable resonators capable of tuning across 1:5:1 frequency band in less than 10us are also on the controlled list. This likely relates to potentially jamming equipment or the ability for frequency hopping of communications devices which would be difficult to track by the military.
Photolithography equipment has made its way into the news on multiple occasions with China trying to purchase ASML equipment. The export-controls on such hardware is to prevent foreign nations from being able to manufacture the latest silicon devices which would enable the creation of more powerful military equipment. While this may seem unfair to other nations, it should be noted that semiconductors are the foundation of the modern military, and controlling their creation is essential to national security.
Unfortunately, unless you are a legal expert who has read all the rules behind exports, the answer is to find a lawyer in export legislation. However, a designer can make some educated guesses and precautions that can help the accidental shipment of restricted components
Firstly, designers can keep up-to-date with government announcements and news reports on global politics and foreign relations. For example, the US and Iran are not on the best terms, and the introduction of sanctions against Iran made headlines. As such, warning alarms should be sounding in the heads of any engineer when sending anything to a nation with sanctions against it (this include Russia, China, and Belarus).
Secondly, designers can look at their designs and try to identify parts of high value. From there, these parts can be googled and their datasheet viewed to see if there are any export controls on such parts. When purchasing parts from major distributors, they will often put notices on parts with such controls.
Thirdly, designers can ask themselves if their product can be used maliciously. For example, while a simple switch can be used as a trigger, it cannot be export-controlled as it is very simple. Instead, designs such as drone control systems that incorporate AI and guidance clearly contain all the hardware needed to create a rocket guidance system. As such, export-controlled devices are often advanced to some degree.
At the end of the day, it is always best to seek legal advice and contact government officials if you intend to send electronics abroad. Generally speaking, it is a minority of countries that have such sanctions against them, and if you are needing to ship electronics to a nation such as Iran, Russia, or China, then you should definitely seek approval from a government entity.