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Collection Highlights

Export Control Law and Regulations Handbook A Practical

Guide to Military and Dual Use Goods Trade Restrictions
and Compliance 3rd edition Yann Aubin

The Gendered and Colonial Lives of Gurkhas in Private

Security From Military to Market Advances in Critical
Military Studies 1st Edition Amanda Chisholm

Military Strategy of Great Powers: Managing Power

Asymmetry and Structural Change in the 21st Century (Cass
Military Studies) 1st Edition Håkan Edström

Courthouse Architecture Design and Social Justice Space

Materiality and the Normative 1st Edition Kirsty
Duncanson
Scoreless Game On the Board 2 1st Edition Anna Zabo L A
Witt

Algebra for Applications Cryptography Secret Sharing Error

Correcting Fingerprinting Compression 2nd Edition Arkadii
Slinko

Gangster s Court 1st Edition Adam Van Susteren

Red Rose Red Thorns Crew 2 1st Edition Rebel Hart

Image Processing Using FPGAs Donald G Bailey Editor

We Have Always Been Cyborgs: Digital Data, Gene
Technologies, and an Ethics of Transhumanism 1st Edition
Stefan Lorenz Sorgner
 NL ARMS
Netherlands
Annual Review
of Military
Studies 2021
Compliance and Integrity in
International Military Trade
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

Robert Beeres · Robert Bertrand ·

Jeroen Klomp · Job Timmermans ·
Joop Voetelink Editors

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 NL ARMS

Netherlands Annual Review of Military Studies

Editor-in-Chief
Patrick Oonincx, Breda, The Netherlands
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Series Information

This peer-reviewed series offers an overview of cutting-edge scientific

research on military sciences drawing on scholarship from researchers at the
Faculty of Military Sciences (FMS) of the Netherlands Defence Academy and
colleagues around the world. Research at the Faculty is military-relevant and
typically multi-disciplinary in nature. It is concerned with themes including
but not limited to:
– The conduct of contemporary war
– Military strategy
– Leadership and ethics
– Military law and history
– Command and control in military operations
– Cyber security
– Operational analysis
– Navigation
– Combat systems
With NL ARMS the Netherlands Defence Academy seeks to contribute to a
growing body of international comparative research in military sciences.

Editorial Office
Faculty of Military Sciences
Netherlands Defence Academy
P.O. Box 90 002
4800 PA Breda
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

The Netherlands

More information about this series at http://www.springer.com/series/13908

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Robert Beeres Robert Bertrand • •

Jeroen Klomp Job Timmermans • •

Joop Voetelink
Editors

NL ARMS Netherlands
Annual Review of Military
Studies 2021
Compliance and Integrity in International
Military Trade
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

123

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Editors
Robert Beeres Robert Bertrand
Faculty of Military Sciences Faculty of Military Sciences
Netherlands Defence Academy Netherlands Defence Academy
Breda, The Netherlands Breda, The Netherlands

Jeroen Klomp Job Timmermans

Faculty of Military Sciences Faculty of Military Sciences
Netherlands Defence Academy Netherlands Defence Academy
Breda, The Netherlands Breda, The Netherlands

Joop Voetelink
Faculty of Military Sciences
Netherlands Defence Academy
Breda, The Netherlands

ISSN 1387-8050 ISSN 2452-235X (electronic)

NL ARMS
ISBN 978-94-6265-470-9 ISBN 978-94-6265-471-6 (eBook)
https://doi.org/10.1007/978-94-6265-471-6
Published by T.M.C. ASSER PRESS, The Hague, The Netherlands www.asserpress.nl
Produced and distributed for T.M.C. ASSER PRESS by Springer-Verlag Berlin Heidelberg

© The Editor(s) (if applicable) and The Author(s) 2022. This book is an open access publication.
Open Access This book is licensed under the terms of the Creative Commons Attribution 4.0
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NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Foreword

Traditionally the Netherlands Defence Academy (NLDA) each year publishes a

volume in this series reflecting on a particular research topic. This year’s topic is
related to both research and the MSc programme on Compliance and Integrity in
International Military Trade (CIIMT). They both focus on a wide variety of sci-
entific ingredients like economics, export control, ethics, and legal aspects. With
this point of view the volume distinguishes itself from what it is common in the
literature on this subject, namely, a monodisciplinary approach. The same breadth
of expert areas is also offered in the corresponding education programme at the
NLDA.
A substantial number of contributions deal with Export Control, which is a
subject of increasing interest for the Ministry of Defence (MOD). A violation of
trade legislation may result in negative consequences like limited access to
military-strategic items and financial claims. The strictest body of regulations is a
United States regime for controlling and restricting the export of military tech-
nologies called the US International Traffic in Arms Regulations (ITAR), which
will of course be considered in this volume.
Although it may seem a relatively new topic, regimes of modern export control
date back to the “Trading with Enemies Act” (USA, 1917) and the “Import, Export
and Customs Power Act” (UK, 1939). ITAR was enacted at a later date during the
Cold War (1976). ITAR’s prominence has increased over the years, leading to the
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

implementation of export compliance programmes by US exporters. Also for the

MOD this prominence and the possible negative consequences gave rise to the
development of more research and education programmes by the NLDA.
Case studies of non-compliance are presented in this book, including its causes,
consequences and ways of working around the control. I am convinced that besides
the theoretical discussions these kinds of analyses provide a better understanding
of the topic, making it more valuable for everyone dealing with the compliance and
export control.
I am very pleased that the authors also included a chapter on the Dutch history of
arms exports in which a historian elaborates on arms exports and arms export
control in the Dutch Republic, from 1585–1621. By then there was already a strong

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 vi Foreword

need for arms export control, far before the US and UK Acts were enacted in the
last century. The interests and benefits yielded by the Republic are analysed in the
last chapter.
Finally I want to congratulate all the authors and editors for this extensive and
thorough overview of this very important topic, which will definitely serve as a very
good background in compliance and integrity in international military trade.

Patrick Oonincx
Dean of Faculty Military Sciences
Netherlands Defence Academy
Breda/Den Helder, The Netherlands
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Contents

1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Robert Beeres, Jeroen Klomp, Job Timmermans, Robert Bertrand
and Joop Voetelink
2 Economics of Arms Trade: What Do We Know? . . . . . . . . . . . . . . 13
Jan van Lieshout and Robert Beeres
3 Export Control Regimes—Present-Day Challenges and
Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Esmée de Bruin
4 Case: Non-compliance at Fokker Services . . . . . . . . . . . . . . . . . . . . 55
Ben Klappe and Mark Keunen
5 International Export Control Law—Mapping the Field . . . . . . . . . 69
Joop Voetelink
6 Exploring the Multifaceted Relationship of Compliance
and Integrity—The Case of the Defence Industry . . . . . . . . . . . . . . 95
Job Timmermans
7 Do Sanctions Cause Economic Growth Collapses? . . . . . . . . . . . . . 115
Melody Splinter and Jeroen Klomp
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

8 Datasets for Combat Aircraft . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

Alsu Saitova and Robert Beeres
9 Does Legal Origin Matter for Arms Control Treaty
Ratification? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 157
Jeroen Klomp and Robert Beeres
10 Case: Sharing Parts and Services Among NATO Members . . . . . . 175
Semra Türkalp and Bastiaan Dekkers

vii

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 viii Contents

11 Limits on the Extraterritoriality of United States Export Control

and Sanctions Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 187
Joop Voetelink
12 Contract-Boundary-Spanning Governance Initiatives
in the International Defense Supply Chain of the F-35
Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 219
Tom De Schryver and Gert Demmink
13 Effectiveness of Arms Control: The Case of Saudi Arabia . . . . . . . 243
Marion Bogers, Robert Beeres and Koen Smetsers
14 Case: Dronebuster; Handling Non-compliance to ITAR . . . . . . . . . 263
Wim Nieboer and Dik van Manen
15 Developing an Adequate Internal Compliance Program
for the Royal Netherlands Air Force Command . . . . . . . . . . . . . . . 271
Robert Bertrand and Hans van Riet
16 Arms Exports and Export Control of the Dutch Republic
1585–1621 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 289
Michiel de Jong
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Editors and Contributors

About the Editors

Robert Beeres holds a Ph.D. in administrative sciences from Radboud University

Nijmegen, The Netherlands. Currently he is a professor of Defence Economics at
the Faculty of Military Sciences, Netherlands Defence Academy. His research
interests include economics of arms export controls, defence capabilities, perfor-
mance management, and burden sharing within the EU and NATO. He published
numerous articles in peer-reviewed journals and books and co-edited a number of
books.

Robert Bertrand colonel Royal Netherlands Marechaussee, is associate professor

of Accounting, Control and Defence Economics at the Faculty of Military Sciences,
Netherlands Defence Academy. He joined the Royal Netherlands Air Force in 1995
and switched to the Royal Netherlands Marechaussee in 2009. He defended his
Ph.D. on contract audits in 2016 at Maastricht University. His current research
interests focus on auditing, compliance, internal control, ethics, and leadership.

Jeroen Klomp is full professor of arms export control at the Faculty of Military
Sciences of the Netherlands Defence Academy and associate professor macroeco-
nomics at the Section Economics of the Wageningen University & Research. He
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

holds a Ph.D. in political economy from the University of Groningen. His current
research involves the economic causes and consequences of strategic trade controls
and has been published in numerous peer-reviewed journals.

Job Timmermans is an associate professor Business Ethics at the Faculty of

Military Sciences of the Netherlands Defence Academy. His interests cover the
philosophical and sociological issues arising from the intersections of ethics,
integrity, and compliance within organisations. Previously, he has worked within

ix

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 x Editors and Contributors

several projects on Responsible Research Innovation (RRI) at Wageningen

University (NL), De Montfort University (UK), and Delft University of Technology
(NL).

Joop Voetelink is associate professor of Law at the Faculty of Military Sciences

of the Netherlands Defence Academy. He defended his Ph.D. on Military
Operational Law at the University of Amsterdam in 2012. Currently, his research
focusses on export control law in general with a specific focus on sanctions,
extraterritoriality, and emerging technologies.

Contributors

Robert Beeres Faculty of Military Sciences, Netherlands Defence Academy,

Breda, The Netherlands
Robert Bertrand Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Marion Bogers Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Esmée de Bruin Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Michiel de Jong Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Tom De Schryver Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Bastiaan Dekkers Royal Netherlands Air Force, Breda, The Netherlands
Gert Demmink Central Bank of the United Arab Emirates, Abu Dhabi, United
Arab Emirates;
Safe Trade Corridors, Abu Dhabi, United Arab Emirates
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

Mark Keunen Kromhout Barracks, Defence Support Command, Utrecht, The

Netherlands
Ben Klappe Materiel and Services, Utrecht, The Netherlands
Jeroen Klomp Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands;
Section Economics, Wageningen University & Research, Wageningen,
The Netherlands
Wim Nieboer NSPA, Capellen, Luxembourg

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Editors and Contributors xi

Alsu Saitova Royal Netherlands Air Force, Breda, The Netherlands

Koen Smetsers Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Melody Splinter Section Economics, Wageningen University & Research,
Wageningen, The Netherlands
Job Timmermans Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Semra Türkalp Royal Netherlands Air Force, Breda, The Netherlands
Jan van Lieshout Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands
Dik van Manen Export Control Compliance Team CLAS, Utrecht, The
Netherlands
Hans van Riet Royal Netherlands Air Force, Breda, The Netherlands
Joop Voetelink Faculty of Military Sciences, Netherlands Defence Academy,
Breda, The Netherlands;
Amsterdam Center for International Law, Amsterdam, The Netherlands
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 Chapter 1
Introduction

Robert Beeres, Jeroen Klomp, Job Timmermans, Robert Bertrand

and Joop Voetelink

Contents

1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.2 The Compliance and Integrity in International Military Trade (CIIMT) Master
Programme . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.2.1 Focus of the MSc Programme on CIIMT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.2.2 Learning Styles and Structure of the MSc Programme on CIIMT . . . . . . . . . . . . 5
1.3 Outline of NL ARMS 2021 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Abstract This year’s volume of the Netherlands Annual Review of Military Studies
(NL ARMS) offers an interdisciplinary view on the domain of Compliance and
Integrity in International Military Trade (CIIMT), integrating defence economics,
international law, arms export control frameworks and policies, information manage-
ment, organizational sciences and ethics. Although in academia, and from an interdis-
ciplinary perspective, CIIMT constitutes a novel research domain, across private and
public defence-related sectors, the subject evokes high levels of attention and interest,
instigating a need for critical thinking, reflection and creativity to address ensuing
multi-faceted issues and problems. From 2017, the Faculty of Military Sciences
(FMS) at the Netherlands Defence Academy (NLDA) has offered an in-house MSc
programme on CIIMT, which, by integrating practice-based and scientific-based

R. Beeres (B) · J. Klomp · J. Timmermans · R. Bertrand · J. Voetelink

Faculty of Military Sciences, Netherlands Defence Academy, PO Box 90002, 4800 PA Breda, The
Netherlands
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

e-mail: [email protected]
J. Klomp
e-mail: [email protected]
J. Timmermans
e-mail: [email protected]
R. Bertrand
e-mail: [email protected]
J. Voetelink
e-mail: [email protected]

© The Author(s) 2022 1

R. Beeres et al. (eds.), NL ARMS Netherlands Annual Review
of Military Studies 2021, NL ARMS,
https://doi.org/10.1007/978-94-6265-471-6_1

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 2 R. Beeres et al.

knowledge, aims to contribute to this need. The NL ARMS 2021 comprises, amongst
others, contributions from students and lecturers partaking in this programme.

Keywords Compliance · integrity · international military trade · (arms) export

control · strategic trade control · strategic trade control frameworks

1.1 Introduction

Re-imposing United States (US) sanctions against Iran, the US-China trade war,
US threats on account of high-technology exports to China from the European
Union (EU), the termination of the US-Russian treaty on Intermediate-Range Nuclear
Forces (INF), the political turmoil surrounding the Nordstream-2 pipeline project,
or selling military-strategic items under the flag of humanitarian support constitute
examples of recent events with potential geopolitical consequences.
The examples above hold another thing in common. To some degree, they are
related to the arms trade. As compared to most other goods, commodities and services,
the international arms trade is extensively controlled. The need to exercise effec-
tive control over international arms transfers is acknowledged, almost globally, and
grounded in specific international regimes, arrangements and treaties, on national
laws and regulations, as well as in standards and principles.
In research, varying concepts are applied to render meaning to control. For
example, military strategists refer to arms control,1 whereas lawyers employ export
control2 and economists arms export control3 to express both similar as well as very
dissimilar control notions, inherent to their domains. Moreover, next to these concepts
of control, in literature, measures such as economic sanctions4 and arms embargoes5
serve as manifest forms of more or less effective controls, and the Financial Action
Task Force, by imposing regulations to counter money laundering and terrorism
financing, also aims to oppose the proliferation of weapons of mass destruction.6
To prevent possible quagmires springing from differences in terminology, NL
ARMS 2021 on Compliance and Integrity in International Military Trade (CIIMT), in
this introductory chapter, applies strategic trade control as an encompassing notion.7
To us, the editors, strategic trade control relates to all efforts undertaken by countries
and international organisations, such as the European Union, to design and implement
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

measures to regulate international movements of military-strategic goods and dual

use items that are able to exacerbate ongoing conflicts, contribute to destabilizing
weapons build-ups, or can be used in violations of human rights. Moreover, the

1 Gray 1992; Smith 2009, p. 87.

2 Aubin and Idiart 2016.
3 Smith and Garcia-Alonso 2006.
4 Afesorgbor 2019.
5 Brzoska and Lopez 2009.
6 Joosten et al. 2019; Stewart et al. 2020.
7 Dill and Stewart 2015; Salisbury 2013.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
 1 Introduction 3

concept of strategic trade control frameworks is applied to clarify variations in the

development, design and operational use of strategic trade controls across nations.
Such clarification is considered necessary as national strategic control frameworks
serve as the foundations underpinning multilateral frameworks.
Strategic trade controls imply strategic relationships between defence-related
public and private sectors, comprising industries, firms, governments, universities
and research institutes, and international institutions. Strategic trade control frame-
works shape the business environment and regulatory contexts in which industries
must operate, navigate and remain aligned to, both nationally and internationally,
in order to conduct and sustain business relating to the transfer of controlled items.
Due to its complex nature and evolving policy landscape, compliance with strategic
trade controls can incur high levels of costs, additional resources, and ongoing
commitments, both from industry and end-users.
Two significant trends have become visible over the last two decades. First, regula-
tions to improve international security are regularly abused for economic purposes,
as illustrated by the recent trade war between China and the US.8 Second, dual-
use items, in particular emerging technologies, are gaining importance. Both trends
instigate novel monitoring issues, thereby rendering strategic trade policies subject
to continuous change.9
Violation of strategic trade legislation may hold severe consequences, for instance,
limited access to military-strategic items, loss of trade privileges, fines, reputational
damage and even prison sentences. In this respect, and compounded by its extraterri-
torial effect, the US International Traffic in Arms Regulations (ITAR) is considered
the strictest body of regulations.10
Compliance with trade control regulations is not only the responsibility of defence-
related industries, but, instead, stretches to encompass end-users, such as the armed
forces. It has to be noted, however, that, in striving to act compliant with trade
control regulations the relation between compliance and integrity remains essential.11
Integrity is the primary requirement in any compliance process, whereas acting ‘in
compliance with’ is understood as an act associated with integrity. Likewise, when
shaping an ethical culture based on integrity, such acting ‘in compliance with’ as
well as the standards that are part of the object of compliance are to be incorporated.
There is no recipe for constructing the best relation between integrity and compli-
ance, for, as such relations are context-dependent, they are being shaped in actual
Copyright © 2021. T.M.C. Asser Press. All rights reserved.

organizational practices. In this regard, build-in mechanisms to gain insight and

awareness on integrity-compliance relations will influence organizational decision-
making processes on trading military goods or services to a suspicious country.
Rather than responding reactively, when particular transactions are causing societal
outrage, an ethical culture enables organizations to act pro-actively, by incorporating

8 Heidenkamp et al. 2013, p. 105; PricewaterhouseCoopers 2005, p. 27.

9 Brandt 1994; Kytömäki 2014; Jones 2020.
10 Heidenkamp et al. 2013, p. 113.
11 Achterbergh and Vriens 2009, pp. 376–377.

NL ARMS Netherlands Annual Review of Military Studies 2021 : Compliance and Integrity in International Military Trade, edited by
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